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Expanding FAPIIS: First "Ownership," Now "Predecessors"

Client Alert | less than 1 min read | 12.17.14

On December 4, 2014, the FAR Councils issued a proposed rule that would require offerors to disclose all "predecessor" entities that held a federal contract or grant within the prior three years, with comments due by February 2, 2015. This information, in addition to the recent addition of ownership information, will be stored in the Federal Awardee Performance and Integrity Information System (FAPIIS).


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.”...