A focus on multinationals: Whistleblower incentives on the international stage
Client Alert | 1 min read | 08.05.21
2020 was one of the first years in memory when many multinationals saw a reduction in the number of internal whistleblower complaints, and a sharp increase in the number of external whistleblower complaints. In this environment, several countries around the world are finding ways to incentivize external whistleblower complaints, including—following the United States’ lead—providing bounties tied to money that governments recover as a result of those complaints. In this article by Crowell & Moring Partner Preston Pugh and Incoming 2022 First Year Associate Danielle Alvarez, part one of a two-part series, we discuss the development of these laws and the specific types of complaints whistleblower bounty laws cover. In part two, we will provide recommendations on how multinationals can best prepare for these developments.
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Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
