False Claims Act Defense Strategies: A CEO’s Road Map From Civil Investigation to Criminal Charges By Theodore P. Watson, Practice Leader US Supreme Court Admitted Attorney, Watson & Associates LLC | Updated September 26, 2026 | 12-minute read A civil investigative demand arrived at your company. Or an agent left… Read more »
A poorly developed size protest can do more than lose a procurement challenge. It can reinforce a competitor’s eligibility, expose weaknesses in the protestor’s legal strategy, and leave the agency record populated with sworn evidence that is difficult to overcome on appeal. That is the central lesson from Size Appeal… Read more »
You did not expect this. A letter arrived — formal, government letterhead, demanding documents, emails, contracts, financial records, and possibly sworn testimony. At the top, it says: Civil Investigative Demand. Now your attorneys are using a phrase you have never heard before: CID hold. If you do not know exactly what… Read more »
If you handle federal set-aside work, the Nisou Enterprises decision is worth reading closely. In Size Appeal of Nisou Enterprises, Inc., SBA No. SIZ-6380 (2026), OHA did not say the challenged contractor was definitely small. What OHA did say is just as important: SBA’s Area Office made critical legal and… Read more »
When a CID Arrives, the Real Risk Often Starts After You Open It For many federal government contractors, the shock is not just that a Civil Investigative Demand (CID) showed up. The bigger shock is how quickly well‑intentioned reactions inside the company can make the situation harder, more expensive, and… Read more »
Government contractors operating in the United States can lawfully employ foreign nationals in some circumstances, but the legal risk rises sharply when immigration compliance, labor practices, security restrictions, set-aside rules, billing representations, and procurement certifications do not line up. For executives facing a subpoena, CID, suspension threat, indictment, or federal… Read more »
A HUBZone problem rarely begins with the words “fraud investigation.” It usually starts with something smaller: an SBA program examination, a certification review, a competitor protest, an employee residency question, a principal office challenge, or a request for records that seems simple enough to answer. Then the issue expands. What… Read more »
A government investigation can become much more dangerous when a company reacts too quickly, destroys or alters records, allows unmanaged employee communications, or tries to “cooperate” without a legal strategy.The right response is disciplined, documented, and directed by counsel so the business can protect its legal position while dealing credibly… Read more »
Federal SDVOSB fraud investigations can escalate quickly from an SBA or VA eligibility issue into a parallel criminal and civil enforcement matter involving the Department of Justice, the False Claims Act, and false-statement charges. Companies and veteran owners accused of SDVOSB misconduct need a defense strategy that addresses procurement rules,… Read more »