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 »
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 »