New Reporting Requirements For Grant and Cooperative Agreement Recipients
Client Alert | less than 1 min read | 09.14.10
On September 14, 2010, OMB issued two regulations implementing the Federal Funding Accountability and Transparency Act of 2006 requirements applicable to recipients of federal financial assistance. The first requires (among other things) that, for any new award made after October 1, 2010, applicants and recipients of grants and cooperative agreements must register in the Central Contractor Registration ("CCR"), and the second requires (among other things) that recipients of grants and other forms of federal financial assistance must (subject to a few limitations that generally mirror those in the FAR) provide information about the recipient's executive compensation, first-tier subawards over $25,000, and subrecipients' executive compensation.
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Client Alert | 3 min read | 04.14.26
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.
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