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GAO Faults Corrective Action Reevaluation

Client Alert | less than 1 min read | 08.27.15

In eAlliant, LLC (Jan. 14, 2015), GAO demonstrated that reevaluations based on "corrective action" must independently pass muster. Here, the record contained no rational basis or explanation for why the official who had previously credited the protester's technical proposal with multiple strengths had allowed the removal of all but one strength during subsequent reevaluations when there were no material revisions to the RFP's technical requirements or to the protester's proposal.


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Client Alert | 3 min read | 08.18.25

FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment

On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines....