GAO: Ongoing DoD Fraud Risk Assessment Efforts Should Include Contractor Ownership
Client Alert | 1 min read | 11.27.19
On November 25, 2019, the Government Accountability Office (GAO) published a report examining risks posed to the Department of Defense (DoD) by contractors with “opaque ownership,” including financial and nonfinancial fraud and national security risks. Among other things, GAO found evidence that opaque ownership structures had been used to fraudulently inflate pricing and circumvent set-aside eligibility requirements in DoD procurements, and had enabled some foreign-owned companies to obtain contracts reserved for U.S. companies, access export controlled information without authorization, and/or misrepresent the country of origin of their offerings in order to meet domestic preference requirements. GAO recommended that DoD assess contractor ownership across DoD to determine whether additional ownership information should be collected to effectively manage potential fraud and national security risks. GAO noted that DoD has already begun a department-wide fraud risk management program, by requesting that DoD components identify risks and controls in place to mitigate these risks by July, 2019. The System for Award Management currently requires contractors to self-report information about their “immediate” and “highest-level” entity ownership – terms that do not necessarily match well with the often-complicated ownership structures of modern business, especially those contractors owned by private equity. This report may well result in additional reporting and certification requirements.
Contacts
Insights
Client Alert | 4 min read | 07.02.26
A Busy Week for Aviation Regulatory Developments
The week of June 29 brought a flurry of regulatory activity from the Department of Transportation (DOT), the Federal Aviation Administration (FAA), and the Transportation Security Administration (TSA) impacting companies across sectors including airlines, supersonic aircraft manufacturers, drone operators, and owners/operators of critical infrastructure facilities. A summary of the key developments is below.
Client Alert | 4 min read | 07.02.26
Logged Out: How LOGZONE's DIBCAC Challenges Put It Squarely in DOJ's Crosshairs
Client Alert | 6 min read | 07.02.26
Client Alert | 3 min read | 07.02.26
Prohibiting Adversarial Patents Act of 2026 (H.R. 9142): What the Drone Industry Needs to Know


