OCI Mitigation Doesn't Go Far Enough
Client Alert | 1 min read | 02.13.06
In Greenleaf Constr. Co. (Jan. 17, 2006, http://www.gao.gov/decisions/bidpro/29310518.pdf), GAO found an unmitigated organizational conflict of interest because the owner of the awardee was to receive a stream of payments from another contractor that the awardee would be overseeing and evaluating and whose economic well-being the awardee therefore could significantly affect. The owner of the awardee had been required by the agency to sell the other contractor in order to avoid having an OCI interest in the profits of that other contractor, but GAO found that the interest of the awardee's owner in ensuring that the other contractor would be able to continue making the payments to him might impair the awardee's objectivity in performing its contract evaluation duties.
Insights
Client Alert | 2 min read | 02.28.25
We previously reported that the Corporate Transparency Act’s Beneficial Ownership Information Reporting Rule (BOI Rule) was back in effect as of February 18, 2025, with a stay of the final nationwide block to enforcement. At that time, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extended the BOI Rule’s reporting deadline until March 21, 2025 (in cases where the originally-applicable deadline had expired) for entities required to report, which includes certain entities formed or registered to do business in the United States (Reporting Companies).
Client Alert | 1 min read | 02.28.25
Client Alert | 3 min read | 02.28.25
Client Alert | 3 min read | 02.27.25
House Committee Seeks Comment on New Comprehensive Data Privacy and Security Framework
