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Richard Arnholt

Richard Arnholt advises companies, large and small, on the complex rules and regulations applicable to grants and contracts from federal and state governmental entities. In an era of increased budgetary pressures for contractors, Richard focuses his practice on providing practical business and legal guidance to help clients efficiently navigate the minefield of government procurement and grant regulations.

On September 17, Florida Attorney General James Uthmeier announced that Starbucks agreed to pay $1 million and undertake several commitments to resolve a lawsuit alleging that Starbucks engaged in employment practices that violated the Florida Civil Rights Act through race- and sex-based goals, quotas, and preferences. The settlement comes amid increased federal enforcement involving similar practices, including recent FCA settlements involving federal contractors Accenture, Deloitte, and IBM.… Continue Reading Starbucks Settlement Adds to Growing Scrutiny of Corporate DEI Programs

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

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.
Continue Reading DOJ Continues DEI False Claims Act Enforcement with $25 Million Accenture Settlement

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.
Continue Reading Deloitte DEI Settlement Highlights False Claims Act Risk at Both Federal and State Levels

As procurement fraud enforcement continues to be a priority for the Department of Justice and other federal agencies, we take a look back at significant 2025 enforcement developments affecting government contractors, grant recipients and participants in federal programs in our 2025 Procurement Fraud Review.

Continue Reading Procurement Fraud Enforcement Trends Continue Into 2026

On April 15, the Federal Circuit issued a decision clarifying the burden a protestor must meet when challenging an agency’s override of the Competition in Contracting Act’s (CICA) automatic stay of performance. In Life Science Logistics, LLC v. United States, the court held that when challenging an override of CICA’s automatic stay of performance after a protest is filed at the GAO, a protestor need not demonstrate entitlement to an injunction under the standard four-factor equitable relief test. Instead, the protestor only needs to show that the agency’s override decision was arbitrary and capricious.

Continue Reading Clarified Standard for Challenging CICA Stay Overrides

On April 30, President Trump issued an Executive Order (Order) directing federal agencies to make fixed-price contracting the default and preferred procurement method across the federal government. The Order reflects the administration’s view that fixed-price contracts better promote cost predictability, contractor accountability, and performance-based outcomes than cost-reimbursement and other non-fixed-price contract types.

Continue Reading President Trump Issues Executive Order Directing Agencies to Default to Fixed-Price Contracting

On April 17, the Federal Acquisition Regulatory (FAR) Council issued guidance implementing Executive Order (EO or Order) 14398, Addressing DEI Discrimination by Federal Contractors, less than 30 days after the Order was signed and well ahead of the 60-day deadline the Order gave the Council to act. Because the Order required agencies to begin implementation within 30 days, the FAR Council likely took quick action to ensure a uniform government-wide approach to implementation of this requirement.

Continue Reading FAR Council Moves Quickly on DEI Executive Order, Which Has Already Been Challenged in District Court

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, and abuse.

Continue Reading 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 Federal Acquisition Regulatory (FAR) Council recently released its long-awaited overhaul of FAR Part 19, the section governing small business programs. While the rewrite is part of the Trump administration’s broader initiative to reduce the FAR to statutory and “essential” provisions, the changes to Part 19 carry significant implications for both small and large contractors.

Continue Reading FAR Part 19 Rewrite: Key Developments for Small Business Contracting