Corruption, Contracts, and Terrorism Financing: The D.C. Circuit Clarifies ATA Risk

Posted on January 27, 2026
Recent litigation in the D.C. Circuit highlights the growing legal risks facing companies operating in conflict-affected and high-corruption environments, particularly where commercial activity intersects with terrorist financing concerns. In Atchley v. AstraZeneca UK Ltd., the court revived claims under the Anti-Terrorism Act (“ATA”) alleging that pharmaceutical and medical equipment companies indirectly financed terrorist attacks...
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GAO Sustains Protest Over CIA’s Faulty Cost Realism Evaluation

Posted on January 6, 2026
In a recent bid protest decision, Markon LLC, B-423767-.4, December 12, 2025, the Government Accountability Officer (GAO) delivered a pointed reminder about the limits of agency discretion in cost realism evaluations. In this case, which involved a solicitation for business operations, information technology engineering support, and business enterprise modernization services, the Central Intelligence Agency...
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Federal Circuit Panel Issues Landmark Decision Addressing Tucker Act Standing and COFC Jurisdiction in Task Order Protests

Posted on June 25, 2024
The Federal Circuit’s recent decision in Percipient.AI, Inc. v. United States represents a major development in its case law regarding bid protest standing and task order protest jurisdiction.  In the decision—which has rightly received significant attention this month—a three-judge panel of the U.S. Court of Appeals for the Federal Circuit held that Percipient, which...
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Lawmakers and Regulators Recognize Crypto and Blockchain Present Unique Problems for Traditional Enforcement Mechanisms

Congressional Democrats Seek Increased Oversight Into Crypto Matters Following Ransomware Attacks A group of Democratic senators and congressmen are calling on the Department of Justice, the State Department, the Department of the Treasury, and Homeland Security to beef up efforts to protect against the recent wave of ransomware attacks. The group, comprised of senators...
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DOJ Announces Creation of Cryptocurrency Enforcement Team

Posted on October 8, 2021
On October 6, 2021, the Department of Justice (“DOJ”) announced the creation of the National Cryptocurrency Enforcement Team (“NCET”) to investigate and prosecute criminal misuses of cryptocurrency. NCET’s particular focus will be on crimes committed by virtual currency exchanges, mixing and tumbling services, and money laundering infrastructure actors, to include the tracing and recovery...
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Civil Cyber-Fraud Initiative to Hold Government Contractors Responsible for Cybersecurity

On October 6, 2021, the Department of Justice (DoJ) announced the Civil Cyber-Fraud Initiative (the “Initiative”) to combat cyber threats, specifically to sensitive information and critical systems of the United States Government (USG). In launching the Initiative, Deputy Attorney General Lisa O. Monaco made clear that a primary focus of the Initiative is to...
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