At the end of March, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory urging financial institutions to heighten scrutiny of transactions potentially tied to healthcare fraud schemes targeting Medicare, Medicaid, and other federal and state healthcare benefit programs. The Advisory is accompanied by this press release.
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President Trump Issues Executive Order Targeting “DEI” Practices by Federal Contractors
By Todd Overman
On March 26, President Trump issued a new Executive Order (EO), Addressing DEI Discrimination by Federal Contractors, that seeks to prohibit federal contractors and subcontractors from engaging in what the EO defines as “racially discriminatory DEI [diversity, equity and inclusion] activities.”…
FinCEN Update: Huge Penalty on Broker-Dealer for Willful AML, SAR, and Due Diligence Failures
On March 6, the Financial Crimes Enforcement Network (FinCEN) announced a historic $80 million civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. FinCEN, which is part of the U.S. Treasury Department, has principal responsibility for administration of U.S. anti-money laundering (AML) and terrorist…
Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China
By Faith Dibble & Thad McBride
On February 11, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Applied Materials, Inc. (AMAT) and Applied Materials Korea, Ltd. (AMK) resolving allegations that the companies illegally reexported U.S.-origin semiconductor manufacturing equipment to China.…
GAO: Conversion Did Not Void Procurement Eligibility
By Todd Overman
In the matter of L3Harris Technologies Integrated Systems L.P., the Government Accountability Office (GAO) denied a protest filed by L3Harris challenging the U.S. Army’s award to Sierra Nevada Company, LLC for the Army’s HADES (High Accuracy Detection and Exploitation Systems) aircraft effort.…
Best Practices for Responding to Government Investigations
We recently co-authored an article for Compliance Week on best practices for responding to government investigations.…
OFAC Enforcement Update: $1.72M Settlement Highlights Screening Gaps in Education, Similar Sectors
On February 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $1.72 million settlement with IMG Academy, LLC (IMG) arising from apparent violations of OFAC’s counternarcotics sanctions program. OFAC is the U.S. government agency with primary responsibility for administering economic sanctions.…
Bid Protest Minute: Pricing Narratives Won’t Save You If Rates Look Unrealistic, GAO Says
By Todd Overman
In T3i, Inc., the Government Accountability Office (GAO) denied T3i’s protest after the Air Force excluded T3i’s low-priced, technically acceptable proposal because the agency found 25 of T3i’s 129 unburdened (gross) hourly labor rates unrealistically low. GAO held that the Air Force’s price realism review was reasonable and consistent with the solicitation, and it rejected…
Bid Protest Minute: GAO Rejects “Should Have Received More Strengths” Protest in $64M Army Task Order Competition
By Todd Overman
On January 14, the Government Accountability Office (GAO) denied a protest filed by Strategic Resources, Inc. (SRI) after the Army issued a task order to360 Patriot Enterprises, LLC (Patriot) for Army National Guard military funeral honors and survivor outreach services.…
SBA Suspends Over 1,000 8(a) Participants After Program-Wide Audit Data Request While DoW Announces Line-By-Line Review of All Small Business Awards Over $20 Million
The U.S. Small Business Administration (SBA) has suspended 1,091 participants in the 8(a) Business Development Program after concluding that those firms did not timely submit required documentation in response to SBA’s recent program-wide data request. The suspensions are part of a broader effort by SBA to audit the 8(a) program and root out fraud, waste,…