On March 9, 2015, Lorraine D’Angelo spoke at the American Road and Transportation Builders Project Management Academy. Her presentation focused on the advantages of having an ethics and compliance program and why “aspiring to the minimum” is not enough anymore. In addition, participants were asked to solve ethical dilemmas typical of those they may face in their daily jobs.
No matter how ethical you think your organization is, the risk of a compliance failure is there. Such a failure or lapse can result in financial, operational, and reputational harm. Some of the sanctions include assessment of huge fines, penalties or forfeiture of money, the imposition of a monitor, suspension or debarment for a period…
DetailsOn February 18, 2015 New York City Comptroller Scott Stringer announced a new initiative that is aimed to increase transparency and accountability on NYC spending. A key provision of the initiative is to report on M/WBE spending in Checkbook NYC. The reports will include detailed data on spending by contractors and agencies. This is part…
DetailsOn January 21, 2015, Lorraine D’Angelo led a group conversation on the benefits and risks of implementing incentives within your organization and E&C program. The ECOA’s Construction and Engineering Group meets quarterly to discuss issues particularly relevant to the engineering and construction industry.
The theory of implied certification under the FCA, at the appellate court level, is alive and well. On January 8, 2015, the Fourth Circuit Court in United States v. Triple Canopy, Inc. reversed a lower court decision dismissing a FCA complaint based upon a theory of implied certification. Essentially, the Fourth Circuit is allowing the case…
DetailsOn January 12, 2015, Lorraine gave a webinar for the American Road and Transportation Association about the recently enacted DBE Regulations which highlighted the more prominent changes to the regulations and offered practical advice for contractors for bringing their programs up to speed.Highlights included advice on the good faith effort changes, what to do when…
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