Compliance

Federal contractors and grant recipients are no strangers to changing requirements and evolving priorities. But in recent months, we’ve seen a noticeable increase in stop work orders, early terminations, and administrative actions that directly impact performance, cash flow, and compliance obligations.

These situations are rarely straightforward. Agencies may issue stop work orders based on shifting funding or political directives. Terminations may stem from compliance findings or performance concerns, even when the root causes are unclear or disputed. Contractors and recipients must be ready to respond quickly with a sound understanding of the legal framework and a plan for recovery.

To help navigate this complex landscape, we’re hosting a webinar on Thursday, June 26 at 1:00 p.m. ET with Donna Dominguez of Aprio.Continue Reading Preparing for the Unexpected: Legal and Strategic Considerations in Federal Contract and Grant Terminations

On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the U.S. Department of Justice (DOJ) laying out the evaluation criteria and a non-exhaustive list of factors the Criminal Division should use to decide whether to pursue a Foreign Corrupt Practices Act (FCPA) case. The FCPA is the primary law by which the U.S. government seeks to prosecute and penalize bribery of non-U.S. government officials.Continue Reading Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

One of President Trump’s campaign themes was ending diversity, equity, inclusion (DEI) programs, and he moved quickly to address those campaign promises. Within days of his inauguration, the president issued two executive orders (EOs) overhauling how the federal government views programs seeking to advance DEI priorities.Continue Reading Implementation of Trump DEI Orders Slower than Expected: What Contractors Should Know

On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The private whistleblower who reported the conduct received over $1.2 million in the matter. As we suggested in a blog post in February, these sorts of enforcement actions will proliferate under the Trump DOJ.Continue Reading DOJ Settlement Highlights Customs, FCA Risks for Importers

On March 14, the U.S. Court of Appeals for the  Fourth Circuit granted the government’s motion for a stay pending appeal, terminating a Maryland district court’s injunction of certain elements of President Trump’s January 20 and 21 diversity, equity and inclusion (DEI) executive orders (EO), “Ending Radical and Wasteful Government DEI Programs and Preferencing” and “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.”  We wrote about the district court’s injunction here and here.Continue Reading Fourth Circuit Terminates Maryland District Court’s DEI Injunction

As the Trump administration continues to eliminate federal positions and reduce contract and grant outlays, many private companies will likely be eyeing current and former government employees for employment over the coming months.  However, companies looking to hire former government employees must keep in mind the strict and nuanced rules that govern their hiring, and, in some cases, prohibit contractors from paying former government employees and limit their ability to appear before their former agencies. Continue Reading Ethics Rules Applicable to Hiring Former Federal Government Employees

A new executive order is set to reshape federal contracting by implementing more stringent transparency measures, but it may also create significant challenges for both government agencies and contractors.Continue Reading Executive Order on Federal Contracting Transparency: Potential Challenges and Implications

On March 3 Judge Abelson of the U.S. District Court for the District or Maryland denied the government’s motion for a stay pending appeal of the preliminary injunction halting the termination of equity-related federal grants and contracts and stopping the imposition of new diversity, equity and inclusion (DEI)-related certification requirements in federal agreements, among other actions required by President Trump’s DEI-related Executive Orders 14151 and 14173. Continue Reading Judge Denies Government’s Motion to Stay Injunction of Anti-DEI Executive Orders

Over the first month of the new administration, President Trump has directed the review or termination of certain types of contracts and grants, including equity-related agreements, awards under the Inflation Reduction Act and the Investment and Jobs Act, and foreign aid agreements awarded by USAID.  Those actions, while disruptive, have been limited to certain agreement types or agencies. Continue Reading Executive Order Directs Systematic Review of “Covered Contracts and Grants” For Possible Termination

From the Bass, Berry & Sims Blog Network
From the Bass, Berry & Sims Blog Network

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