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Investigation and Disclosure Best Practices

Client Alert | less than 1 min read | 06.06.16

In Importance of Disclosures and Cooperation During and After Internal Investigations, Crowell & Moring attorneys review several recent regulatory changes and highlight the growing importance of targeted communication with the government before, during, and after internal investigations. Among other things, the article lists suspension and debarment statistics taken from the System for Award Management for the first half of fiscal year 2016 to demonstrate the importance of, and benefits that may be achieved from, targeted communication to the government by experienced government contracts investigations attorneys.

Insights

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....