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Eleventh Circuit OK’s Suspension of Affiliates Beyond 18 Months

Client Alert | 1 min read | 01.08.14

In Agility Def. & Gov’t Servs. v. Dep’t of Def. (Dec. 31, 2013), the Eleventh Circuit reversed the judgment below and held that when an agency suspends a contractor it may suspend affiliates of that contractor for greater than 18 months based solely on their affiliation provided legal proceedings have been initiated during that period against the contractor. The district court had held that the regulations required affiliation-based suspensions to be lifted after 18 months unless legal proceedings had been initiated against the affiliates themselves, but the Eleventh Circuit held that affiliates are afforded sufficient due process and that no independent showing of wrongdoing by an affiliate is required for suspension or debarment.


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Client Alert | 4 min read | 04.09.26

DOJ Establishes National Fraud Enforcement Division

On April 7, 2026, Acting Attorney General Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (NFED) within the U.S. Department of Justice (DOJ). This new division will be dedicated to the centralized, coordinated investigation and prosecution of fraud against taxpayer dollars and taxpayer-funded programs. AAG Blanche acknowledged that, while DOJ has a “storied history of combatting fraud,” DOJ has “never adopted a comprehensive and coordinated approach to investigating and prosecuting fraud against taxpayer dollars and tax-payer funded programs.” The NFED was created to close that gap with its core mission being to “zealously investigate and prosecute those who steal or fraudulently misuse taxpayer dollars.”...

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