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The V&E Report
Insights in Government Enforcement and Investigations

GAO Urges DOD To Systematically Assess Fraud Risks Related to Contractor Ownership

On November 25, 2019, the Government Accountability Office (“GAO”) published a report examining the financial and nonfinancial fraud and national security risks to the Department of Defense (“DoD”) when contractors employ “opaque ownership structures.” GAO defined opaque ownership structures as those that conceal or obfuscate entities or individuals who own, control, or benefit financially from the contractor.

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  • 09
  • October
  • 2019


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DOJ’s Civil Fraud Director Addresses Recent FCA Policy Developments

On September 19, 2019, speaking at the Practising Law Institute’s Government Contracts 2019 event, Michael Granston, the Director of the Civil Fraud Division at the Department of Justice (“DOJ”), provided an update on the government’s enforcement activities under the False Claims Act (“FCA”).1 Granston’s comments focused on three key areas of recent DOJ FCA policy: (1) the use of agency guidance documents, (2) the dismissal of qui tam lawsuits by DOJ, and (3) cooperation credits for FCA defendants.

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Truth or Cyber-Consequences: Government Contractor Suspended After Suffering Cyberattack and Data Breach

Government contractors that expose government information to cyberattacks may face suspension from doing business with the Federal Government. Perceptics, LLC suffered a highly publicized cyberattack that was revealed in June 2019, and the decision of U.S. Customs and Border Protection (“CBP”) to suspend the company demonstrates the severe consequences that government contractors face if they fail to protect against cyberattacks or to comply with contractual cybersecurity obligations.

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