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
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
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
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
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