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GAO: Ongoing DoD Fraud Risk Assessment Efforts Should Include Contractor Ownership

Client Alert | 1 min read | 11.27.19

On November 25, 2019, the Government Accountability Office (GAO) published a report examining risks posed to the Department of Defense (DoD) by contractors with “opaque ownership,” including financial and nonfinancial fraud and national security risks. Among other things, GAO found evidence that opaque ownership structures had been used to fraudulently inflate pricing and circumvent set-aside eligibility requirements in DoD procurements, and had enabled some foreign-owned companies to obtain contracts reserved for U.S. companies, access export controlled information without authorization, and/or misrepresent the country of origin of their offerings in order to meet domestic preference requirements. GAO recommended that DoD assess contractor ownership across DoD to determine whether additional ownership information should be collected to effectively manage potential fraud and national security risks. GAO noted that DoD has already begun a department-wide fraud risk management program, by requesting that DoD components identify risks and controls in place to mitigate these risks by July, 2019. The System for Award Management currently requires contractors to self-report information about their “immediate” and “highest-level” entity ownership – terms that do not necessarily match well with the often-complicated ownership structures of modern business, especially those contractors owned by private equity. This report may well result in additional reporting and certification requirements.

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Client Alert | 3 min read | 08.03.26

New Jersey Takes Aim at Algorithmic and Surveillance Pricing: What Landlords and Retailers Need to Know About the FAIR Act and the Fair Price Protection Act

On July 20, 2026, New Jersey Governor Mikie Sherrill signed the Forbidding the Algorithmic Inflation of Rent (FAIR) Act into law, making New Jersey the fourth state to regulate algorithmic rent-setting practices. Three days later, on July 23, 2026, Governor Sherrill signed the Fair Price Protection Act, which targets “surveillance pricing”—the practice of using or collecting personal data about a user and using an algorithm or artificial intelligence to charge different consumers different prices for the same products. Together, these laws represent a significant expansion of New Jersey's consumer protection framework in the algorithmic pricing context....