Flawed Pension Cost Decision Is Reversed - But Why?
Client Alert | less than 1 min read | 05.20.08
Last year, the ASBCA held in Raytheon Corp., ASBCA No. 54907, 07-2 BCA 33,655, that contractors are noncompliant with CAS requirements if they do not complete the segment closing adjustment required by CAS 413 for pension costs within the same fiscal year as the segment closing and determined that the interest due on CAS noncompliances is subject to compounding daily. On April 30, 2008, the Board reversed that decision on reconsideration, holding, without explanation, that the Government could not have suffered any damage as a result of the so-called noncompliance, making its prior holding about the calculation of interest moot and, therefore, dicta.
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.”
Client Alert | 2 min read | 03.11.26
Client Alert | 3 min read | 03.11.26
Civil Litigation as a First-Response Strategy: The UK Government's Fraud Strategy 2026–2029
