Separate CAS Noncompliances May Get Separate SOL
Client Alert | 1 min read | 01.22.14
In Appeal of Fluor Corp., the ASBCA held that the government's claim relating to an alleged CAS 403 noncompliance "was a continuing claim inherently susceptible to being broken down into a series of independent distinct events," namely, each payment by the government for a CAS-non-compliant billing. Thus, the board held that, under the CDA's statute of limitations, the government "knew or should have known" that it had a claim against the contractor as of the date the compliance audit was completed (for amounts paid before that date), but that claims for the same alleged CAS noncompliance in subsequent years would not accrue until the amounts at issue for those years had been billed and paid, a result that may save some government claims from the CDA's 6-year SOL (previously discussed here, here, here, here, and here).
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Client Alert | 4 min read | 07.22.26
On July 17, 2026, the United States Department of Justice (DOJ) announced that it had entered into a Deferred Prosecution Agreement (DPA) with The Scoular Company (Scoular), an agricultural supply chain company based in Omaha, Nebraska, to resolve allegations that Scoular relied on customs brokers to bribe Mexican government officials to allow Scoular goods to pass customs inspections and be delivered to Mexico from the United States. As part of its resolution, Scoular agreed to pay a $9,769,521 criminal penalty and forfeit an additional $414,351. Scoular also committed to continue cooperating with DOJ on any ongoing or future criminal investigations, implement a compliance and ethics program designed to prevent and detect violations of the Foreign Corrupt Practices Act (FCPA), and periodically report to DOJ on remediation and implementation of compliance measures throughout the term of the DPA.
Client Alert | 4 min read | 07.22.26
Ghost Advertising: Compliance Takeaways From the Gymshark Influencer Class Action
Client Alert | 5 min read | 07.21.26
Client Alert | 5 min read | 07.20.26
