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The Confusing World of Compensation Caps

Client Alert | less than 1 min read | 01.13.14

As a result of the confusing, inconsistent, and in some cases unenforceable changes made in the cost allowability rules setting caps on compensation costs in recent months, it is difficult to determine what rules apply to some contracts. We prepared the attached chart, which we hope will be useful, summarizing our understanding of the various sets of regulatory and statutory provisions that are likely to be applicable to currently active contracts as a tool for deciding how many alternative indirect cost submissions could be required.


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. ...