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BPAs: They Ain't Contracts

Client Alert | less than 1 min read | 02.14.14

In Crewzers Fire Crew Transport, Inc. v. U.S. (Feb. 6, 2014), the Federal Circuit reaffirmed that a blanket purchase agreement is not typically a binding contract on which the contractor can sue. In this instance, as in many, the necessary "mutuality of obligation" was negated in both directions, with the BPA expressly saying the agency was not obligated to make an award under the BPA and that the contractor was not obligated to accept any order proffered by the agency.


Insights

Client Alert | 3 min read | 03.12.26

DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy

On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”...