Section 8B2.1 of the 2007 version of the United States Sentencing Commission Guidelines define and “effective compliance and ethics program” for purposes of section (f) of § 8C2.5 for the Culpability Score and section (c)(1) of §8D1.4 for Recommended Conditions of Probation – Organizations: (a) To have an effective compliance and ethics program, for purposes [...]
Tag Archives: Federal
Contingent Fee Arrangements in Government Contracts
Section 3.400 of the Federal Acquistion Regulations limit the ability of the federal governmen to enter into contingent fee arrangements. Federal contracts require the insertion of the Covenant Against Contingent Fees: (a) The Contractor warrants that no person or agency has been employed or retained to solicit or obtain this contract upon an agreement or [...]
Anti-Kickback Act
The Anti-Kickback Act of 1986, 41 U.S.C. § 51 et seq., modernized and closed the loopholes of previous statutes applying to government contractors. The 1986 law attempts to make the anti-kickback statute a more useful prosecutorial tool by expanding the definition of prohibited conduct and by making the statute applicable to a broader range of [...]
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