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Proposed NRO Clause Would Require Broad Disclosure -- Comments Due Tomorrow

Client Alert | 1 min read | 02.12.04

The proposal of the National Reconnaissance Office (NRO) to add a new standard clause to its contracts that would provide that "contractors and their employees, agents, representatives, subcontractors, and employees of subcontractors shall report to the NRO Inspector General (IG) or General Counsel any and all possible violations of federal criminal law or illegal intelligence activities of which they become aware during performance under an NRO contract," make all relevant records and employees available to the IG (failure to do so grounds for default termination), and flow the clause down to subcontractors raises obvious and serious policy issues. The request for comments are due tomorrow, February 13, despite only being published on February 4, on the NRO website, where the full text of the proposed clause is available.

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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs....

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