Steven D. Gordon

Steven D. Gordon

Holland & Knight LLP

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Latest Publications


Justice Department Reveals How It Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

3/20/2017 - Compliance Corporate Misconduct Corruption DOJ Enforcement Actions FCPA Fraud Policies and Procedures Risk Assessment Third-Party Relationships White Collar Crimes

State, Local Taxes on Tribal Leases Vulnerable After California Court Order

Indian country may be close to another victory against state and local taxes. On Feb. 8, 2016, a California district court issued an order that signals it is likely to invalidate Riverside County's imposition of a possessory...more

3/4/2016 - Bureau of Indian Affairs Carried Interest Tax Rates Leases Native American Issues Tribal Lands

D.C. Circuit Upholds FTC Ruling on Deceptive Advertising; Rejects First Amendment Challenge

In a much-awaited decision on Friday, January 30, the D.C. Circuit upheld the Federal Trade Commission’s decision that pomegranate juice maker POM Wonderful LLC engaged in false or misleading advertising by claiming its...more

2/9/2015 - Advertising Clinical Trials Commercial Speech False Advertising First Amendment FTC POM Wonderful

It’s Time to Re-Think the False Claims Act

The federal False Claims Act (FCA) is one of the government’s primary weapons in combating fraud by federal contractors, federal grantees and recipients of federal benefits. Since 1986, when the FCA was restructured into its...more

7/25/2014 - Enforcement Enforcement Actions False Claims Act (FCA) Federal Contractors Fraud Qui Tam Whistleblowers

New Legislation Would Revamp Suspension and Debarment

On October 29, 2013, the House Oversight and Government Reform Committee approved a bill to restructure suspension and debarment from federal procurement and non-procurement programs. The Stop Unworthy Spending (SUSPEND) Act...more

11/5/2013 - Department of Defense (DOD) Oversight Committee Suspensions & Debarments

D.C. Circuit Invalidates Lengthy Exclusion

A recent decision by the D.C. Circuit underscores the large amount of discretion that federal agencies have in determining the length of a debarment or exclusion imposed on a government contractor or program participant....more

10/16/2012 - EPLS Kathleen Sebelius Pharmaceutical Industry Suspensions & Debarments

Suspensions and Debarments of Government Contractors Increase

Last year Congress and the Office of Management and Budget pushed federal agencies to become more aggressive about suspending and debarring contractors. In October of 2011, a Government Accountability Office report found that...more

9/27/2012 - EPLS GAO Suspensions & Debarments

Establishing a Culture of Ethical Behavior and Legal Compliance: Finding Perspective After Penn State and the Freeh Report

Ethical behaviors and legal compliance within any educational institution cannot be presumed; they must be cultivated, monitored and enforced. It is a team effort. It begins with senior leadership, including an informed and...more

9/24/2012 - Child Abuse Penn State Sexual Abuse

Suspension and "Guilt by Association"

A recent federal court decision highlights two important issues relating to excluding contractors from participation in federal government contracting: (1) suspension, and (2) "affiliation."...more

7/13/2012 - Affiliates Contractors Federal Acquisition Regulations (FAR) Fraud Suspensions & Debarments

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