1. Home
  2. |Insights
  3. |Another Salvo in the War for Control of Contractor "Systems" Approval

Another Salvo in the War for Control of Contractor "Systems" Approval

Client Alert | 1 min read | 08.20.10

In the "Report on Allegation of Unsatisfactory Conditions Regarding Actions by the Defense Contract Management Agency, Earned Value Management Center" (July 28, 2010 http://www.dodig.mil/Audit/reports/fy10/apo/D-2010-6-002.pdf), the DoD Inspector General recommended that the Defense Contract Management Agency "prohibit joint surveillance reviews or other joint activities with a contractor" in order to avoid compromising DCMA's "independence" and to take action to increase DCAA "participation" in Earned Value Management Systems audits. While DCMA did not concur in many of the recommendations in the IG report, if the IG recommendations were adopted they would inevitably be applicable to other contractor "systems" issues, make it more difficult for contracting officers to resolve systems issues raised by DCAA, and have a decidedly negative impact on compliance and contract administration activities in the procurement process.

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. ...