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DoD Broadens Allowability for Cost Associated with Counterfeit Electronic Parts

Client Alert | 1 min read | 09.01.16

On August 30, 2016, DoD published a final rule that expands allowability of costs of actual or suspect counterfeit electronic parts and the cost of rework or corrective action due to their use. Whereas, previously, such costs were only allowable if the parts were government-furnished property, effective August 30, 2016, such costs will also be allowable if the parts are obtained in accordance with the newly added DFARS 252.246-7008 concerning sourcing of electronic parts; the contractor becomes aware of the part through inspection, testing, authentication, or other means; and it provides notice to the cognizant COs and GIDEP within 60 days of becoming aware.

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Client Alert | 3 min read | 04.14.26

DOJ’s False Claims Act Resolution Against IBM Signals Heightened Risk for Federal Contractors with DEI Programs

On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded....