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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.

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Client Alert | 7 min read | 10.29.26

7th EU Competition Law Conference, co-hosted by Crowell & Moring, King’s College London and the Competition Law Center at George Washington University

On 8 October 2026, Crowell & Moring, King's College London, and the Competition Law Center at George Washington University co-hosted the 7th EU Competition Law Conference at De Warande in Brussels. Mark Meador, Commissioner at the US Federal Trade Commission (FTC), delivered the opening keynote address, followed by four panels bringing together practitioners, regulators, academics, and in-house counsel to discuss the latest developments in EU, UK, and US competition law enforcement. Among other things, the panels examined algorithmic pricing; the European Commission's (Commission) new guidelines on exclusionary abuses under Article 102 TFEU (Article 102 Guidelines); the impact of dominant positions in merger reviews; and lessons from the enforcement of the Digital Markets Act (DMA) and the UK’s Digital Markets, Competition and Consumers Act. ...