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Failure To Update Invalidates Evaluation And Responsibility Determination

Client Alert | 1 min read | 02.17.06

In Greenleaf Constr. Co. (Jan. 17, 2006, http://www.gao.gov/decisions/bidpro/29310518.pdf), GAO held that the awardee's failure to advise the agency of changes to its proposed plan for performance which arose after submission of its final proposal revision, including different key personnel and a different software system, invalidated the technical evaluation based on the original proposal. GAO also invalidated the contracting officer's responsibility determination as to the adequacy of awardee's financial resources because the contracting officer knew that an affiliated company that had provided most of the revenues of the awardee's corporate family in the DCAA analysis had been sold.

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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.”...