Additional Business Systems Reviews Proposed
Client Alert | less than 1 min read | 07.17.14
The government issued a proposed rule on Monday that would require contractors subject to withholdings under the Business Systems Rules to conduct annual internal reviews of their accounting, estimating, and material management and accounting business systems and engage an independent CPA firm to conduct audits every three years (or more frequently if directed by the contracting officer). The proposed rule if adopted as drafted would likely result in inefficiency and delay because it contemplates DCAA review and approval of the independent CPA work plan, audit, and workpapers and permits DCAA to challenge the findings of the independent CPAs.
Insights
Client Alert | 3 min read | 04.23.24
DOJ Promises NPAs to Certain Individuals Through New Voluntary Self-Disclosure Pilot Program
On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department.
Client Alert | 3 min read | 04.23.24
Client Alert | 5 min read | 04.23.24
Client Alert | 6 min read | 04.23.24
