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 | 6 min read | 11.19.25
The facts before the Third Circuit in the recently decided case of Patel v. United States illustrate how parties can put themselves in a bind if they make factual admissions when resolving a criminal case involving fraud on the government while not simultaneously resolving the government’s civil claims under the False Claims Act (FCA) for the same underlying conduct.
Client Alert | 4 min read | 11.18.25
DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes
Client Alert | 6 min read | 11.18.25
Client Alert | 2 min read | 11.14.25
