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VA Consolidates Fraud Detection, Prevention, and Enforcement Efforts

Client Alert | 1 min read | 06.08.17

Continuing the Trump Administration’s focus on fraud, waste, and abuse, Veterans Affairs Secretary Dr. David Shulkin announced a program to consolidate fraud detection, prevention, and remediation efforts in VA administered programs. The program, called Seek to Prevent Fraud, Waste, and Abuse (STOP FWA), consolidates fraud prevention and remediation efforts within VA health, benefits, and cemeteries programs and is expected to partner with other federal agencies to leverage best practice in fraud prevention, detection, and enforcement. Information sharing among fraud detection and remediation programs has accelerated in recent years across the government, and contractors are well served to consider a holistic approach to investigating (and, if needed, disclosing) misconduct because it is increasingly likely that multiple government stakeholders will be interested in the outcome.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

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