Déjà Vu: Congress Orders DCAA to Revise Guidance on Access to Internal Audit Reports
Client Alert | 1 min read | 01.15.13
Section 832 of the FY 2013 NDAA requires DCAA to issue new guidance on access to contractors' internal audit reports to "ensure" that requests for access to them "are appropriately documented," following guidance issued by the agency in August 2012. The revised guidance will require DCAA to keep tabs on such requests and responses to them, but sets limits on what internal audit reports can be used for and stops short of language in the Senate version of the bill, under which the contractor's refusal to provide access would have been "a basis for disapproving the contractor business system or systems."
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Client Alert | 3 min read | 04.25.24
JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy
The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs.
Client Alert | 6 min read | 04.25.24
Client Alert | 3 min read | 04.24.24
Client Alert | 2 min read | 04.24.24
FTC Continues Focus on Tracking Technologies and Personal Health Data
