Investigations, Enforcement, & Compliance Alerts

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May 1, 2025

15 min read

Future FCA Enforcement Expectations in Light of New Administration Priorities and 2024 Recoveries

The annual False Claims Act (FCA) recovery statistics issued by the U.S. Department of Justice for Fiscal Year 2024, coupled with the Trump administration’s
focus on the elimination of waste, fraud, and abuse in government spending and apparent intentions to rely on the FCA to pursue other administration
priorities, signal a likely increase in FCA investigations and actions throughout 2025 and beyond....Read more

March 20, 2025

13 min read

Fourth Circuit Allows Immediate Enforcement of DEI Executive Orders: Implications for Federal Contractors and Grant Recipients

On March 14, 2025, in a late Friday decision, a panel of judges from the U.S. Court of Appeals for the Fourth Circuit ruled that, for the time being, the Trump
Administration is permitted to enforce Executive Orders (EOs) 14151 (Ending Radical and Wasteful Government DEI Programs and Preferencing) and 14173
(Ending Illegal Discrimination and Restoring Merit-Based Opportunity), which prohibit Diversity, Equity, and Inclusion (DEI) (also referred to as Div...Read more...Read more

February 19, 2025

3 min read

GSA Announces FAR Deviations to Enforce Executive Orders for Government Contractors

On February 15, 2025, the acting administrator of the United States General Services Administration (GSA), Stephen Ehikian, announced on X (formerly
Twitter) that the GSA issued several new deviations from the Federal Acquisition Regulation (FAR) intended to implement key Trump Executive Orders that aim
to end illegal discrimination, restore merit-based opportunity, and eliminate the forced use of paper straws in procurement....Read more

February 7, 2025

15 min read

What to Do After Receiving a Stop-Work Order or Termination of Your Federal Contract or Grant: A Practice Guide for Government Contractors and Recipients

The early days of the Trump Administration have caused nothing less than a complete shake-up of the federal procurement system, with impacts on federal
contractors, subcontractors, and recipients of federal financial assistance, such as grants and loans. Through a series of Executive Orders and Agency
Memoranda issued by the heads of the Office of Management and Budget (OMB), General Services Administration (GSA), Department of State, a...Read more...Read more

January 31, 2025

10 min read

Understanding and Addressing Increased FCA Exposure Risks Resulting from DEI-Focused Executive Order

On January 21, 2025, President Trump issued a sweeping executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (EO).
The EO targets diversity, equity, inclusion, and accessibility (DEI) programs in the public and the private sectors. The EO signals that organizations receiving
federal funds, whether through government contracts or otherwise, may be liable under the False Claims Act (FCA)—one of the government’s m...Read more...Read more

January 29, 2025

7 min read

As Trump Hits Pause on Certain Federal Financial Assistance Programs, Including for Grants and Loans, What Are Recipients’ Rights and Remedies?

On January 27, 2025, the White House published Memorandum M-25-13, titled “Temporary Pause of Agency Grant, Loan, and Other Financial Assistance
Programs.” In an unprecedented move, the initial Memo appeared to suspend all funding for all federal grants, cooperative agreements, noncash
contributions or donations of property, direct appropriations, food commodities, other financial assistance, loans, loan guarantees, interest subsi...Read more...Read more

About This Blog

Winston & Strawn’s Investigations, Enforcement, & Compliance Alerts highlight and analyze significant issues and developments in government investigations, enforcement, civil and criminal trial defense and litigation, compliance, and related matters, providing insights on the legal and strategic implications for individuals and corporations conducting domestic and international business.