Disclosing Fraud by Principals
Client Alert | 1 min read | 03.17.16
In ALGESE 2 s.c.a.r.l. v. U.S. (Mar. 14, 2016), the Court of Federal Claims provided guidance on the terms “principal” and “criminally . . . charged” in the FAR responsibility certification when it enjoined the Navy from proceeding with an award to a company because the Navy should have found it non-responsible upon learning of the corruption and fraud of its parent corporation during a protest of a parallel contract before the GAO. Examining the structure of the company’s family of corporations and conduct, the CFC highlighted that essentially none of the related entities disclosed the many criminal investigations, charges, and convictions in SAM and FAPIIS because the family had “created a new subsidiary in which to dump its criminal liability problems."
Contacts
Insights
Client Alert | 4 min read | 11.09.26
CMS Finalizes Its 2026 Organ Procurement Organization Rule
On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions:
Client Alert | 4 min read | 11.09.26
Pentagon Oversight: Defense Companies Should Prepare for the Next Congress
Client Alert | 7 min read | 11.05.26
2026 State Attorney General Elections: What Businesses Should Expect
Client Alert | 3 min read | 11.05.26
Federal, State, and Local Regulators Sue Toast Over B2B Advertising and Subscriptions
