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Internal Investigations

Clients engage our group to determine risk and exposure to compliance and other legal violations within their organizations. We utilize our experience, knowledge. and judgment to guide clients through an array of challenging strategic decisions including how to respond to a pending government investigation or whether a pre-emptive disclosure is necessary. We advise government contractors and their employees with respect to enforcement requests, inquiries, and subpoenas issued by the Department of Justice, inspector generals, other executive agencies, state attorney generals, and local government enforcers. Clients rely on us for responding to internal audits and investigations; scoping mandatory and voluntary disclosures; and navigating civil and criminal fraud, export control, and grand jury investigations covering industries as diverse as defense and aerospace, construction, electronics, financial services, professional services, information technology, healthcare, pharmaceuticals, and medical devices and equipment.

Experience Highlights

  • Fluor in persuading DOJ to decline intervention in 2018 after sprawling, multi-year protracted investigation, in a qui tam action relating to management of hundreds of millions of dollars-worth of materials on a contingency contract performed in Afghanistan. After a 7-week jury trial in 2026, we obtained defense verdicts on two substantive FCA claims and one FCA retaliation claim. Jury returned liability verdict on one FCA claim for small fraction of the damages sought.

  • Large defense contractor in successfully resolving allegations of cybersecurity non-compliance in 2026 for less than cost of litigation and no admission of liability after an internal investigation and responding to DOJ Civil Investigative Demands.

  • Large defense contractor in successfully responding to an Air Force/DOJ investigation regarding a potential Procurement Integrity Act violation and a request for information from the agency’s suspension and debarment official regarding the contractors’ present responsibility where no action was taking against the company.

  • Large technology company in successfully resolving a DOJ FCA investigation related to allegations of bid-rigging and other anticompetitive conduct on government contracts. We made several presentations to DOJ and ultimately reached a favorable settlement for the clients.

  • University in investigations relating to foreign influence, U.S. federal grants, export compliance, and false claims.

  • Large defense contractor in an FCA investigation related to use of Chinese-sourced magnets in vehicles and weapons systems. After we made productions and presented evidence demonstrating our client’s compliance with contract terms, DOJ/DCIS did not pursue investigation further.

  • Large defense contractor in an FCA investigation that originated from a 2017 DCAA audit. In 2021, presented evidence to DOJ demonstrating that allegations of non-disclosure of cost or pricing data were wrong. In 2022, DOJ dropped investigation.