Government Contracts & Investigations

Category: Fraud, False Claims, and False Statements

Federal Contractors’ Compliance Responsibilities Just Got Easier, or Did They?

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On July 14, 2020, the Federal Acquisition Regulatory (FAR) Council issued an interim final rule intended to clarify the scope and application of the requirements set forth in Section 889(a)(1)(B) of the FY2019 National Defense Authorization Act (FY19 NDAA). The rule’s release comes after months of eager anticipation by—and almost apocalyptic warnings from—a wide varietyRead More

Topics: Ethics and Compliance, Fraud, False Claims, and False Statements

Expeditious Crackdowns on COVID-Relief Fraud

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In the span of mere days, the Department of Justice (DOJ) arrested and charged numerous individuals from Virginia, Massachusetts, Texas, and Ohio, alleging that they fraudulently sought Paycheck Protection Program (PPP) loans under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. At John F. Kennedy Airport, a Virginia couple was arrested on June 20Read More

Topics: Fraud, False Claims, and False Statements

Beware Rogue Employees with a Taste for Fraud

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As if more evidence were needed, a recent Department of Justice (DOJ) indictment provides another reminder of the importance of an effective compliance program—and the potential costs to contractors if their program doesn’t prevent fraudulent actions by individual employees. Last week, the DOJ announced it has entered into a non-prosecution agreement (NPA) with Alutiiq InternationalRead More

Topics: Fraud, False Claims, and False Statements

Flouting Affiliation Rules When Pursuing Small Business Set-Asides Can Lead to FCA Woes

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If you were somehow still wondering whether small businesses really need to be concerned about the affiliation rules in the Small Business Administration (SBA) regulations, the answer is a resounding “Yes.” Furthermore, running afoul of those rules can easily lead to liability under the False Claims Act (FCA), as most recently demonstrated by an OklahomaRead More

Topics: Fraud, False Claims, and False Statements, Small Business / Socioeconomic Issues

PPP Forgiveness Application Certification May Lead to Enforcement Headaches

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I. Introduction The Paycheck Protection Program (PPP) was enacted as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act on March 27, 2020. Unfortunately, the path to providing PPP loan relief has not been smooth. Instead, it has been paved with uncertainty. While the CARES Act laid out specific requirements for PPP eligibility and relief, theRead More

Topics: Fraud, False Claims, and False Statements, Statutes and Regulations