In the corporate investigations and white-collar defense arena, the COVID-19 pandemic will raise a host of untested issues for businesses. A widely dispersed, remote workforce will pose new challenges — legal, technical and ethical — for corporate internal investigations. As the government disburses the largest stimulus package in American history, false claims allegations — civil complaints and criminal charges – will arise. With so much at stake, there will be intense enforcement scrutiny of potential violations of the federal bribery, anti-kickback and honest-services provisions. Similarly, with so many federal dollars flowing through the system and with such urgency that they be applied, there will be both opportunities and danger for companies that contract with the federal government.
An innocent misstatement, ill-executed accounting practice or unethical business partner can open up a range of civil, criminal or administrative penalties for federal contractors – especially in the healthcare arena. One outcome of the coronavirus may be a slew of debarment investigations and criminal pleas for defense contractors. We have the experience and expertise to help guide clients through these unique times.
