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DOJ's Procurement Collusion Strike Force Amps Up Its Enforcement Ranks

Client Alert | 1 min read | 11.13.20

Just days after the anniversary of its launch, the Department of Justice’s Procurement Collusion Strike Force has expanded its ranks to include 11 new national partners. The U.S. Air Force Office of Special Investigations and the Department of Homeland Security’s Office of Inspector General, as well as nine additional U.S. Attorneys’ Offices, have joined the government’s effort to combat collusion, fraud, and antitrust crimes in the public procurement process. Assistant Attorney General Makan Delrahim promised “even more success” for the PCSF in the coming year “[b]y growing [its] national footprint, and folding in additional subject-matter experts.” The PCSF currently has more than 360 agent, analyst, and other law enforcement and OIG working members, hailing from 46 unique agencies and offices at the federal, state, and local levels.

This expansion – on top of news that DOJ has appointed Daniel Glad, former assistant chief of the Chicago field office, as the PCSF’s first permanent director – underscores the Antitrust Division’s continued focus on potential antitrust violations involving public procurement and the increased importance of enlisting counsel experienced in both antitrust and government contracts.

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...