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Surety Liability Under the False Claims Act

The federal Miller Act requires government construction contracts over $100,000 to be bonded. This process involves insurance companies, known as “sureties,” who issue payment or performance bonds to contractors, who in turn...more

Read the Fine Print: Does Your Bid Bond Cover Substitute Performance Costs?

The Federal Acquisition Regulation ("FAR") contains numerous standard and optional forms for use in acquisitions. A standard form (SF) is considered mandatory. For instance, any bilateral or unilateral modification to a...more

Fourth Circuit Adopts Objective Reasonableness Standard in Determining Scienter Element of the False Claims Act

The Fourth Circuit, in United States ex rel. Sheldon v. Allergan Sales, LLC, No. 20-2330, 2022 WL 211172 (4th Cir. Jan. 25, 2022) recently upheld the dismissal of False Claims Act (“FCA”) lawsuit brought by a quit tam relator...more

DOJ Reports False Claims Act Recoveries for Fiscal Year 2021

After reporting its lowest annual recovery from False Claim Act (“FCA”) cases in Fiscal Year (FY) 2020, the Department of Justice (“DOJ”) has reportedly bounced back. On February 1, 2021, DOJ released detailed statistics...more

Federal Acquisition Regulatory Council Expands Scope of Federal Contractor COVID-19 Vaccine Mandate

On Friday, October 1, 2021, a full week ahead of its October 8 deadline, the Federal Acquisition Regulatory Council (“FAR Council” or “Council”) issued a Federal Acquisitions Regulation (“FAR”) deviation contract clause that...more

It’s Finally Here! And it Applies Broadly: The Safer Federal Workforce Task Force Releases Safety Guidance for Federal Contractors

As directed by President Biden’s September 9, 2021 Executive Order 14042, “Ensuring Adequate COVID Safety Protocols for Federal Contractors,” today the Safer Federal Workforce Task Force issued workplace safety guidance...more

Proposed Rule Seeks Major Changes to Buy American Requirements

The Biden-Harris Administration recently made another step forward in bolstering American manufacturing, and by extension American national and economic security. Billed as the “most robust changes to the implementation of...more

More Enforcement is on the Way: The COVID-19 Fraud Enforcement Task Force

Since the dawn of the historic COVID-19 relief packages, which have doled out approximately $2.6 trillion to date (with more to be spent), the federal government has made no secret of the fact that it intends to ferret out...more

US Court of Federal Claims Clarifies the Statute of Limitations for CDA Anti-Fraud Claims

While most federal contractors are eminently familiar with the False Claims Act (“FCA”)—government’s most potent weapons for prosecuting false claims—the anti-fraud provision of the Contract Disputes Act (“CDA”) does not...more

Biden Administration Issues Executive Order 14005 Aimed at Strengthening Made in America Laws

Executive Order 14005 - Not even one week into the Biden Administration’s tenure, Buy American rules are yet again taking center stage as a fundamental policy objective. On January 25, 2021, President Biden issued...more

DOJ Reports False Claims Act Recoveries for Fiscal Year 2020

No one was immune from the impacts of the COVID-19 pandemic in 2020, and that includes the Department of Justice (“DOJ”). After years of steady decline in False Claims Act (“FCA”) recoveries, DOJ reported its lowest annual...more

Money for Nothing—Except Potential False Claims Act Liability

CARES Act - The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act (P.L. 116-136) was passed by Congress and signed into law by President Trump on March 27, 2020. The CARES Act provides over $2 trillion of...more

Department of Justice Issues Updated Guidance on Evaluation of Corporate Compliance Programs

On June 1, 2020, the Criminal Division of the US Department of Justice (“DOJ”) released  an updated guidance document for white-collar prosecutors on the evaluation of corporate compliance programs....more

Civilian Board of Contract Appeals Decision Provides Guidance to Contractors Seeking to Recover Additional Costs Due to COVID-19

While the global economy grinds to a halt over spread of the novel coronavirus (COVID-19) and people disband amidst calls for “social distancing,” these are uncertain times to say the least....more

DOD Issues Class Deviation and Implementation Guidance for CARES Act Section 3610 Authorizing Potential Recovery by Federal...

On April 8, 2020, the Department of Defense (“DOD”) issued Class Deviation Number: 2020-00013 authorizing Contracting Officers (“COs”) to deviate from the principles listed in Federal Acquisition Regulation (“FAR”) Part 31...more

Maryland Governor Orders Closing All Non-Essential Businesses and Other Establishments

On March 23, 2020, Maryland’s Governor Larry Hogan issued three executive orders addressing the COVID-19 emergency: (1) Order 20-03-23-01 closing non-essential businesses throughout the state of Maryland, (2) Order...more

DC Mayor Orders Closure of Non-Essential Businesses and Prohibition on Large Gatherings

On March 24, 2020, District of Columbia Mayor Muriel Bowser issued Mayor’s Order 2020-053: Closure of Non-Essential Businesses and Prohibition on Large Gatherings During Public Health Emergency for the 2019 Novel Coronavirus...more

Virginia Governor Orders Restrictions on Restaurants, Recreational Facilities, Entertainment Venues, Large Gatherings,...

On March 23, 2020, Virginia’s Governor Ralph Northam issued Executive Order No. 53, placing restrictions on restaurants, recreational facilities, entertainment venues, large gatherings, non-essential retail businesses, and ...more

Federal Procurement Procedures During a National Emergency

On March 13, 2020, President Trump declared a national emergency in response to the coronavirus (COVID-19) outbreak. Such a declaration has significant implications on the contracting community navigating the federal...more

OFCCP Issues Updated Technical Assistance Guide for Federal Construction Contractors and Subcontractors

Seyfarth Synopsis: The Office of Federal Contract Compliance Programs has released its long anticipated updated Technical Assistance Guide for Federal Construction Contractors and Subcontractors. ...more

President Trump to Restore Tariffs on Aluminum and Steel Imports from Brazil and Argentina

While China commands the media spotlight in the global war on trade, new trade battles are being waged south of the equator. On Monday December 2, 2019, President Trump announced that he would reinstate tariffs on aluminum...more

President Trump Issues Third Installment of Buy American Initiative

President Trump continues to push forward with his “Buy American, Hire American” initiative with the issuance of his third Executive Order No. 13881 (the “Order”) on July 15, 2019, entitled “Maximizing Use of American-Made...more

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