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."
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Client Alert | 5 min read | 03.28.25
HHS Announces “Dramatic Restructuring”
On March 27, 2025, HHS announced a “dramatic restructuring” of its various agencies and offices in accordance with President Trump's Executive Order, “Implementing the President’s ‘Department of Government Efficiency’ Workforce Optimization Initiative.” HHS also published a Fact Sheet.
Client Alert | 10 min read | 03.27.25
FinCEN Axes Corporate Transparency Act’s Reporting Obligations for U.S. Companies and U.S. Persons
Client Alert | 3 min read | 03.27.25
Client Alert | 3 min read | 03.27.25
MoCRA Under the Trump Era: A Look at FDA's Monitoring and Enforcement Two Months In