On April 10, 2026, the Department of Justice (“DOJ”) announced a $17 million civil False Claims Act (“FCA”) settlement with IBM Corporation. This is the first FCA settlement reached under
Continue Reading First DEI Settlement Under the Civil Rights Fraud Initiative Targets Conduct Pre-Dating the Current AdministrationFCA 101: Materiality
This is the fourth blog in a series on the False Claims Act (FCA), 31 USC §§ 3729, et seq., which targets any person that knowingly submits false claims for
Continue Reading FCA 101: MaterialityWhat GSA’s New Draft AI Procurement Clause Could Mean for Your GSA Schedule Contract
On March 6, 2026, the General Services Administration (“GSA”) published a draft contract clause, GSAR 552.239-7001, “Basic Safeguarding of Artificial Intelligence Systems,” that would establish binding requirements for contractors
Continue Reading What GSA’s New Draft AI Procurement Clause Could Mean for Your GSA Schedule ContractHow to Prepare for the End of the Government Shutdown
On the evening of November 9, the U.S. Senate agreed to a deal aimed at ending the government shutdown. The deal is the first step toward reopening the federal government
Continue Reading How to Prepare for the End of the Government ShutdownShould I Appeal My Terminated Grants in District Court or the Court of Federal Claims?
In 2025, the government has canceled or discontinued billions of dollars in federal grants. Entities seeking to challenge these terminations have faced uncertainty as to which forum is appropriate for
Continue Reading Should I Appeal My Terminated Grants in District Court or the Court of Federal Claims?FAR 2.0 Update: Parts 6, 29, and 31 Released
The Trump Administration, in collaboration with the Federal Acquisition Regulation (FAR) Council, has released further FAR sections as part of the Revolutionary FAR Overhaul (RFO): FAR Parts 6, 29, and
Continue Reading FAR 2.0 Update: Parts 6, 29, and 31 ReleasedOCIs: Recent GAO Decision Provides Insight on How to Successfully Challenge an Agency’s Investigation of Organizational Conflicts of Interest
The Federal Acquisition Regulation (FAR) generally requires contracting officials to identify and evaluate organizational conflicts of Interest (OCIs) as early as possible in a procurement. The FAR also requires the
Continue Reading OCIs: Recent GAO Decision Provides Insight on How to Successfully Challenge an Agency’s Investigation of Organizational Conflicts of InterestSupreme Court Broadly Interprets Wire Fraud Liability
On May 22, 2025, the Supreme Court held that a defendant could be convicted of federal wire fraud pursuant to 18 USC § 1343 even when the fraud did not
Continue Reading Supreme Court Broadly Interprets Wire Fraud Liability
DOJ Announces New Civil Rights Fraud Initiative Targeting DEI
Deputy Attorney General Todd Blanche issued a memo on May 19, 2025, announcing the DOJ’s establishment of the Civil Rights Fraud Initiative. The initiative will “utilize the False Claims Act
Continue Reading DOJ Announces New Civil Rights Fraud Initiative Targeting DEIUpdate: FAR 2.0 Rollout Underway
In what is sure to be an on-going series, we have the latest update regarding the FAR 2.0 rollout.
You can see my opening thoughts on the FAR 2.0 initiative
Continue Reading Update: FAR 2.0 Rollout Underway