Non-Offeror Has Standing, and FAR Part 12 Commercial Item Restrictions Apply to GSA Schedule Procurements
Client Alert | less than 1 min read | 03.12.15
In CGI Fed. Inc. v. U.S.(Mar. 10, 2015), the Federal Circuit held that CGI was a "prospective offeror" and therefore had standing to pursue its preaward protest, despite the fact that CGI did not submit a proposal, which was due after CGI filed at GAO but before CGI filed at the CFC. The Federal Circuit also reversed the CFC on the merits, holding that the proscription in FAR part 12 of terms that are inconsistent with customary commercial practice does apply to solicitations for orders under FAR 8.4 (Federal Supply Schedule) contracts.
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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 | 3 min read | 03.12.26
Client Alert | 2 min read | 03.11.26
