The Department of Justice (DOJ) continues to use the False Claims Act (FCA) to pursue government contractors for alleged failures to comply with contractual cybersecurity requirements. On September 1, DOJ announced that Honeywell Aerospace Inc. agreed to pay $2,042,518 to resolve allegations that a Honeywell business unit failed to comply with required cybersecurity controls under a Department of War (DoW) contract. The settlement is the latest example of DOJ treating cybersecurity compliance as more than an information technology issue. For federal contractors, deficiencies in required cybersecurity controls can also create significant FCA exposure.
Continue Reading “DOJ’s $2 Million Honeywell Settlement Under the Civil Cyber-Fraud Initiative: What Compliance Failures Mean for Defense Contractors
CAS Board Raises Contract Thresholds to $35 Million and Eliminates CAS 407: What Federal Contractors Need to Know as DoW Demands Cost and Pricing Transparency
Federal contractors are heading into October with significantly different cost accounting rules, while defense contractors are also facing renewed pressure to provide the government with greater visibility into their costs and pricing.
On September 1, the Cost Accounting Standards (CAS) Board issued two final rules, both effective October 1, that substantially reduce the reach of CAS. Most notably, the Board increased the basic CAS applicability threshold from $2.5 million to $35 million and doubled the thresholds for full CAS coverage and Disclosure Statements from $50 million to $100 million. In a separate rule, the Board eliminated CAS 407, which governs the use of standard costs for direct material and direct labor, after concluding that Generally Accepted Accounting Principles (GAAP) and other CAS requirements adequately address most of the same issues.
Continue Reading CAS Board Raises Contract Thresholds to $35 Million and Eliminates CAS 407: What Federal Contractors Need to Know as DoW Demands Cost and Pricing Transparency
DOJ Continues DEI False Claims Act Enforcement with $25 Million Accenture Settlement
On September 14, the U.S. Department of Justice (DOJ) announced that Accenture Federal Services (AFS), Accenture plc, and Accenture LLP (collectively, Accenture or AFS) agreed to pay $25 million to resolve allegations that AFS violated the False Claims Act (FCA) by falsely certifying compliance with anti-discrimination requirements in its federal contracts while engaging in employment practices that allegedly discriminated based on race or sex. Of the $25 million settlement, approximately $11.6 million constitutes restitution, and Accenture denies that it engaged in the alleged conduct.
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BIS Settlement Highlights Russia Export Control Risks for EAR99 Items and Third-Country Transactions
On August 24, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $1 million settlement with Ohio-based Container Manufacturing Ltd. (CML) to resolve allegations that the company exported restricted industrial parts to Russia without authorizations required under the Export Administration Regulations (EAR). According to BIS, the violations occurred between March 2023 and March 2025, and included parts valued at approximately $265,000. Notably, two of the shipments involved violations made with knowledge, which may explain a penalty amount nearly four times the value of the underlying transactions.
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Deloitte DEI Settlement Highlights False Claims Act Risk at Both Federal and State Levels
The U.S. Department of Justice (DOJ) announced on August 25 that Deloitte has agreed to pay $21.5 million to resolve allegations that certain diversity, equity, and inclusion (DEI) practices discriminated against employees and applicants based on race or sex and caused the company to submit false claims for payment under federal contracts. The settlement is the latest enforcement action under DOJ’s Civil Rights Fraud Initiative and follows an April settlement in which IBM agreed to pay approximately $17 million to resolve similar allegations.
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BIS Settlement Highlights Export Control Risks for Medical and Research Technology
On August 14, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Plexon, Inc., a Texas neuroscience technology company. BIS asserts that Plexon exported neural recording systems to a restricted Chinese research institution without appropriate authorization under the U.S. Export Administration Regulations (EAR). The EAR is the set of regulations that control exports of U.S. dual-use items; BIS is the main government agency responsible for administering and enforcing the EAR.
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OFAC Settlement Highlights Iran Sanctions Risks for Non-U.S. Subsidiaries of U.S. Companies
On August 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $60,764 settlement with Rice Lake Weighing Systems (Rice Lake), a Wisconsin-based manufacturer of scales and other weight measuring equipment, to address apparent violations of U.S. sanctions on Iran. The violations were committed by Dini Argeo S.r.l. (Dini), Rice Lake’s Italian subsidiary.
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SBA Finalizes New Social Disadvantage Standard for 8(a) Program
The U.S. Small Business Administration (SBA) has finalized a significant change to how small businesses establish social disadvantage for purposes of the 8(a) Business Development Program. Effective September 10, 2026, SBA will eliminate the longstanding regulatory presumption that members of certain racial and ethnic groups are socially disadvantaged and replace it with a single standard available to applicants regardless of race. The rule also eliminates the existing narrative-based test for establishing individual social disadvantage, which SBA has applied to all individually owned applicants since the Ultima decision.
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DOJ’s First FCPA Deferred Prosecution Agreement of 2026 Highlights Cartel-Linked Corruption Risks
On July 17, the U.S. Department of Justice (DOJ) announced that The Scoular Company (Scoular), a Nebraska-based agricultural supply chain company, agreed to pay more than $10 million to resolve allegations that it used third-party customs brokers to bribe Mexican officials facilitating shipments across the U.S.-Mexico border.
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OFAC Launches Reconsideration Portal to Streamline Delisting Petitions
On June 29, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) launched an online Reconsideration Portal for requests to remove persons or property from OFAC sanctions lists, including the Specially Designated Nationals and Blocked Persons (SDN) List. OFAC states that the portal streamlines delisting petitions by collecting key information upfront rather than through repeated questionnaires.…
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