Court Explores New Frontier On The OCI Front
Client Alert | less than 1 min read | 10.17.07
In Axiom Resources Mgmt., Inc. v. U.S. (Sept. 28, 2007), the Court of Federal Claims held that an alleged unequal access to information organizational conflict of interest had not been adequately mitigated because, inter alia, the mitigation plan was not enforceable, as by court order. Also, before determining whether to issue an injunction, the court requested an amicus brief from the Federal Trade Commission Bureau of Competition on several issues, including whether the awardee should be required to divest several contracts, and whether non-disclosure agreements, perhaps similar to those typically involved in establishing appropriate firewalls, unduly restrict future competition.
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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.”
Client Alert | 3 min read | 03.12.26
Client Alert | 2 min read | 03.11.26

