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GAO Finds "Classic Example" Of Impaired Objectivity OCI

Client Alert | less than 1 min read | 09.10.04

In PURVIS Systems, Inc. (Aug. 16, 2004), GAO held that the Navy failed reasonably to consider or evaluate potential organizational conflicts of interest ("OCI") created by the awardee's role in evaluating performance of undersea warfare systems that have been manufactured either by the awardee or its competitors. GAO rejected the awardee's contention that no OCI issues could be created by the awardee's evaluation of the systems because such work was not "part of the procurement process" and explained that the situation presented a "classic example" of an "impaired objectivity" OCI.

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Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....