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Déjà Vu: Congress Orders DCAA to Revise Guidance on Access to Internal Audit Reports

Client Alert | 1 min read | 01.15.13

Section 832 of the FY 2013 NDAA requires DCAA to issue new guidance on access to contractors' internal audit reports to "ensure" that requests for access to them "are appropriately documented," following guidance issued by the agency in August 2012. The revised guidance will require DCAA to keep tabs on such requests and responses to them, but sets limits on what internal audit reports can be used for and stops short of language in the Senate version of the bill, under which the contractor's refusal to provide access would have been "a basis for disapproving the contractor business system or systems."


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Client Alert | 3 min read | 08.18.25

FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment

On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines....