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GSA Transactional Rule Pilot Program – Understanding the Seismic Shift

Client Alert | less than 1 min read | 08.29.16

The GSA’s Transactional Data Rule Pilot Program has been rolled out for certain schedules, but many questions remain for contractors, including the logistical challenges related to the monthly compilation of data, the ability of GSA contracting officers to compare products and services accurately as the agency moves from commercial pricing to horizontal pricing analysis, and the areas of potential liability under this new program. This article by C&M attorneys, published in Bloomberg BNA, provides a detailed explanation of the new rule and practical considerations for government contractors.

Insights

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. ...