Sequestration: The Prequel
Client Alert | 1 min read | 09.26.12
On July 31, 2012, the Defense Procurement and Acquisition Policy (DPAP) office issued a "class deviation" to implement the provisions of section 808 of the 2011 National Defense Authorization Act which prohibit DOD from spending more on contracts for services in 2012 and 2013 than it spent in 2010. The "deviation" requires that CO's set negotiation objectives that do not exceed the labor rates and overhead rates that were in effect during 2010 for the same services, but because the "deviation" also requires that award of any contract that was priced based on rates in excess of those negotiation objectives must be approved by the secretary of the relevant military department or the head of the contracting activity, many DOD CO's are treating the "deviation" as a cap on allowable labor and overhead rates, regardless of any justification that may exist for rate increases.
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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
