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Flawed Discussions Nixes Award

Client Alert | less than 1 min read | 06.11.12

In KPMG LLP (May 21, 2012), GAO sustained a challenge to CIA's conduct of discussions, finding the agency misleadingly informed KPMG that proposals should include resumes for all proposed personnel, yet the awardee proposed – and CIA accepted – only representative resumes, which allowed the awardee to offer a lower cost. GAO also found CIA's cost realism evaluation inadequate, stressing that CIA's evaluation documentation reflected "no meaningful consideration" of whether cost reductions associated with the awardee’s technical approach would actually occur.

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Client Alert | 3 min read | 04.23.24

DOJ Promises NPAs to Certain Individuals Through New Voluntary Self-Disclosure Pilot Program

On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department. ...