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 | 3 min read | 04.25.25
Arkansas Takes Aim at PBM Ownership of Retail Pharmacies
On April 17, 2025, Arkansas recently became the first state to enact broad restrictions on pharmacy benefit managers (“PBMs”) owning retail pharmacies within the state.
Client Alert | 3 min read | 04.23.25
Auto Dealers: Buckle-Up Enhanced State-Level Enforcement Ahead
Client Alert | 2 min read | 04.23.25
Client Alert | 11 min read | 04.23.25