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Chutzpah Goes Unrewarded

Client Alert | less than 1 min read | 02.24.06

The contractor in Armour of Am. v. U.S. (CFC Feb. 14, 2006) alleged "no cause of action" when it argued that it should not have been terminated for default when it was obvious from its offer that it could not meet the mandatory requirements of the RFP/contract and the FAR required the agency to reject nonconforming offers. Still alive, though, is the issue of whether the agency breached its good faith duties by making the award with actual knowledge of the nonconformity and then defaulting early on in the program.

Insights

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.”...