Paul Pompeo counsels a wide range of companies in government contract formation, performance, and compliance, and has done so for over 30 years. Much of his practice focuses on accounting, cost and pricing: Cost Accounting Standards (CAS), the Truthful Cost or Pricing Data Act (formerly TINA), Federal Acquisition Regulation (FAR) cost principles, and Defense Contract Audit Agency (DCAA) audits. He also represents clients in dispute resolution: claims, appeals (before the ASBCA, CBCA, and Court of Federal Claims), and alternative dispute resolution (ADR), as well as bid protests and Competition in Contracting Act (CICA) overrides. He has successfully represented contractors in precedent-setting CAS cases, many involving benefits issues, litigated a seminal Limitation of Cost clause case as well as several involving cost allowability and penalties for expressly unallowable costs, and litigated a series of cases establishing law fundamental to the statute of limitations. He also has experience with Foreign Military Sales (FMS), counsels clients on mergers and acquisitions, financing, appropriations, and contract negotiations, and advises research universities, educational institutions and FFRDCs on compliance with issues stemming from grants and agreements. In addition, Paul handles various fraud matters, including the False Claims Act (FCA), and internal investigations. He is included in Band 1, the highest ranking achievable, of Chambers USA: America's Leading Lawyers for Business for Government Contracts.

Paul served as vice president and general counsel, Government Division of Johnson Controls Inc., and as Ethics Officer. Accordingly, he has an acute sense of clients' needs and how outside counsel can best serve its customer. Paul is a former member of the firm's Hiring and Diversity Committees, and is a past-chair of the firm's LGBT affinity group.


  • Triple Canopy, Inc., in the successful recovery of amounts withheld on security contracts arising, in part, from the consequences of an after-imposed Iraqi law implicating the ability to perform security contracts in the country through an Alternative Dispute Resolution procedure. Triple Canopy, Inc. v. Dep’t of State, CBCA No. 6538 (May 5, 2022).
  • GardaWorld Federal Services, in the successful defense against an Army motion for summary judgment seeking to reduce payments on security contracts. Board held that the government had not demonstrated diminished value under the Inspection and Acceptance clause. Aegis Defense Serv., LLC d/b/a/ GardaWorld Defense Serv., ASBCA Nos. 62442, et al. (March 30, 2022).
  • Top Five Defense Contractor: Provided counseling and negotiation to bring about resolution and recovery of a $172M deficit arising from a CAS 413-50(c)(12) pension curtailment (February 25, 2022).
  • ACADEMI, LLC in securing a favorable settlement through an Alternative Dispute Resolution (ADR) proceeding involving penalties for allegedly expressly unallowable costs, imposition of unilateral rate determinations, and allowability of certain direct costs. The issues spanned three fiscal years. ACADEMI LLC, ASBCA Nos. 60886 et al., (March 1, 2022).
  • Telos in securing a favorable settlement in a matter involving the government’s issuance of a unilateral rate determination that challenged two underlying cost accounting practices. Telos Corp., ASBCA No. 62950 (Dec. 16, 2021).
  • Major defense nonprofit organization in a False Claims Act investigation, including DCIS and CID subpoenas, arising out of alleged unallowable costs charged to government contracts (plus substantial penalties alleged for expressly unallowable costs) in a Defense Contract Audit Agency audit report. We successfully represented the client throughout the investigation and settled with the US Attorney on a non-False Claims Act basis for an amount that was a fraction of the unallowable costs alleged.
  • ACADEMI Training Center LLC, in securing a successful resolution, by alternative dispute resolution, on a contractor claim of approximately $12M and a government claim of approximately $3.6M involving the interpretation of purported caps on G&A, ODC, and fringe rates. ACADEMI Training Center LLC, ASBCA Nos. 61977, 62296 (April 2, 2021).
  • Telos in securing a judgment in favor of Telos involving the government's refusal to reimburse upward adjustments arising from finalized indirect rates on an Air Force contract under government theories of Limitation of Cost and Limitation of Funds clause. Telos Corp., ASBCA No. 62600 (March 3, 2021).
  • GardaWorld Federal Services in the successful defense of a bid protest brought by SOC LLC involving an award of a $58M Department of State contract to provide security services at the US Embassy in Bangui, Central African Republic. SOC LLC, B-418487.2, .3, Feb. 4, 2021, 2021 CPD ¶ ___.
  • L3Harris Technologies in the successful resolution of a contract dispute involving a change in cost accounting practice through alternative dispute resolution. L3Harris Technologies, ASBCA No. 62474 (Feb. 9, 2021).
  • L3Harris Technologies in securing a judgment before the Armed Services Board of Contract Appeals in favor of L3Harris for a deficit arising from a pension segment closure under Cost Account Standard 413. L3Harris Technologies, Inc., ASBCA No. 62438 (June 2, 2020).
  • Booz Allen Hamilton in the successful resolution of a dispute involving a government claim for adjustment of fee with the full withdrawal of the government claim. Booz Allen Hamilton, ASBCA No. 62570 (Jul. 23, 2020).
  • LSQ Funding Group LC successfully resolved a unique Assignment of Claims Act dispute through alternative means. LSQ Funding Group, L.C., v. United States, No. 18-1848C (Fed. Cl. 2020).
  • Raytheon Company in two precedential decisions involving changes in cost accounting practices; key holdings: Government abuse of discretion by failing to apply materiality standards in assessing a cost impact; identifying bases for determining costs immaterial Raytheon Co., Space & Airborne Sys., ASBCA No. 58068, 16-1 BCA ¶ 36484; and Government double counted cost impact by including effect on fixed price contracts; Contractor entitled to offset multiple changes prior to 2005. Raytheon Co., Space & Airborne Sys., ASBCA Nos. 57801 et al., 15-1 BCA ¶ 36024.
  • Raytheon Company in a case where the government asserted a noncompliance with CAS 405 and penalties for expressly unallowable costs involving bonus and incentive compensation costs for employees engaged in activities under FAR 31.205-1 (advertising), -22 (lobbying), -27 (M&A) and -47 (legal), as well as the costs of Total Shareholder Return under FAR 31.205-6(i); key holdings: narrow definition of expressly unallowable costs, bonus and incentive compensation are not expressly unallowable under FAR 31.205-1, -22 and -27; Government's failure to state a claim regarding contribution costs; viability of the doctrine of retroactive disallowance. Raytheon Company, ASBCA Nos. 57801 et al., 15-1 BCA ¶ 36024.
  • Triple Canopy, Inc.: We successfully represented Triple Canopy against a government claim that the company improperly included $62 million of subcontractor costs for dog handlers under the labor categories per the 2005 version of FAR 52.232-7, Time and Materials. The contractor included a Maropakis-style counterclaim asserting entitlement to $64 million pursuant to the terms of the contract and proposal. Triple Canopy, Inc. v. United States, C-291 (Fed. Cl., Jul. 29, 2015) (dismissed).
  • Computer Sciences Corporation: We successfully represented CSC against a government claim that the company included certain unallowable and expressly unallowable costs as direct costs under an IRS contract. The government ultimately withdrew its claim. Computer Sciences Corp. v. Department of the Treasury, CBCA No. 4917 (Sept. 11, 2015) (dismissed).
  • Raytheon Company in a series of precedent-setting cases establishing law fundamental to the Statute of Limitations: Raytheon Company v. US, 104 Fed. Cl. 327 (2012) recon. denied, Raytheon Company v. US, 105 Fed. Cl. 351 (2012); Raytheon Co., ASBCA Nos. 57576, 57679, 13-1 BCA ¶ 35209; Raytheon Missile Sys., ASBCA 58011, 13-1 BCA ¶ 35241; Raytheon Co., Space & Airborne Sys., ASBCA Nos. 57801 et al., 13-1 BCA ¶ 35319.
  • Raytheon Company in a seminal case before the ASBCA, whereby Raytheon contested a government claim for $40.7MM (plus compound daily interest) for increased costs in the aggregate due to a change in accounting practice involving the measurement of pension costs. (Raytheon Co., ASBCA No. 56701, 11-1 BCA ¶ 34753).
  • Drafted opinion regarding allowability of costs associated with implementing offset obligations under new guidance from the United Arab Emirates.
  • Major defense contractor in the successful conversion of a termination for default to termination for convenience.
  • Major defense contractor in a successful resolution of a DCAA denial of access to records action involving foreign subsidiaries and international reciprocal audit agreements resulting in withdrawal of denial of access.
  • Conducted investigation and prepared response to Dept. of Justice subpoena involving a qui tam action resulting in Government declination on the case.
  • Raytheon Company in the Government's withdrawal of a determination of noncompliance with CAS 413.50(b)(2) whereby the Government sought a $300 million contract price adjustment.
  • Major aerospace defense contractor in drafting opinion letter regarding the allowability of a $400 million settlement of a shareholder derivative lawsuit and $11 million in attorney fees to defend the lawsuit.
  • Major aerospace defense contractor sought to recover $7 million in indirect costs for prior, closed, and final indirect cost-rate agreements. Through creative theories and negotiation sessions with the Government, the client recovered more than $4 million.
  • Advanced Systems Development, Inc. in seminal CICA override case. Advanced Sys. Dev., Inc. v. United States, 72 Fed.Cl. 25 (2006).


ASBCA Rejects Statute of Limitations Defense on Incurred Cost Proposal
GovCon Legal Update (pdf)
Speaker, Dixon Hughes Goodman’s 26th Annual Government Contracting Conference
Federal Circuit Affirms Ebola Cost Recovery Case with Potential COVID Implications
Government Contracts Update
Presenter, Public Contracting Institute
Statute of Limitations Trends from 2020
Arnold & Porter Webinar


The Legal 500 US
Government Contracts (20162022)
Chambers USA
Government Contracts (Nationwide) (20092022)
Government Contracts: Costs Disputes—"Spotlight Table" (Nationwide) (20162022)
Washington, DC Super Lawyers
Government Contracts (20132015, 20172020)


  • LLM, The George Washington University Law School, 1991
  • JD, Catholic University of America, Columbus School of Law, 1988
  • BS, State University of New York at Albany, 1985, magna cum laude
  • District of Columbia
  • Supreme Court of the United States
  • US Court of Appeals for the Federal Circuit
  • US Court of Federal Claims
Government & Military Service
  • Staff Counsel, Postal Service Board of Contract Appeals, US Postal Service
  • National Defense Industrial Association (NDIA): Chair, Procurement Division (2017 - 2018); Chair, Contract Finance Committee (2014 - 2015) Legal Committee
  • American Bar Association, Public Contract Section: Co-Chair, Accounting, Cost and Pricing Committee (2005-2008)
  • Advisory Board, Government Contractor
  • Advisory Board, Government Contract Costs, Pricing & Accounting Report (2006-2009; 2019-present)
  • National Contract Management Association (NCMA)
  • Board of Contract Appeals Bar Association
  • Court of Federal Claims Bar Association
  • American Corporate Counsel Association (1998-2002)
  • Federal City Performing Arts Association Board of Directors (2006-2009)
  • DC Cabaret Network
  • DC Front-runners
  • A native of New York City, Mr. Pompeo has retained interest in cultural activities. He sings semi-professionally, performing cabaret in the Washington-Baltimore area. He has sung with several symphonic choruses, appearing with both the National Symphony Orchestra and the Baltimore Symphony Orchestra. Mr. Pompeo sang at the Opening Ceremonies for the 2009 Inauguration of President Obama.

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