Foreign Corrupt Practices Act
Defense and government contractors face one of the sharpest FCPA enforcement concentrations of any sector, where the U.S. Department of Justice and the U.S. Securities and Exchange Commission have repeatedly used the statute's anti-bribery and books-and-records provisions to pursue conduct tied to foreign procurement, offset arrangements, and third-party agent networks. The U.S. Department of Defense's own contractor compliance expectations, layered on top of DOJ's Corporate Enforcement Policy, mean that a single deficient internal investigation can convert a disclosed violation into a debarment risk. Cresthaven is actively monitoring this intersection for new enforcement actions, policy guidance, and agency statements as they land.
Watch
- DOJ Corporate Enforcement Policy: how voluntary disclosure credit applies to contractors
- Third-party agent vetting under FCPA in offset and co-production deals
- SEC books-and-records enforcement against dual-use technology exporters
- Debarment consequences when FCPA settlements involve government contracts
- Foreign military sales intermediaries flagged in recent DOJ declination letters
Recent material activity in Defense & Government Contracting
GAO dismisses Aero Simulation bid protest challenging Air Force exclusion from competitive range
The Government Accountability Office dismissed Aero Simulation, Inc.'s protest on September 4, 2026 in B-424444, ending the challenge to the Department of the Air Force's decision to exclude ASI from further consideratio…
Read a full sample brief →ASPI strategic analysis identifies space AI as a capability solution for Southeast Asia's maritime surveillance deficit
The Australian Strategic Policy Institute published an analysis on September 4, 2026 examining how artificial intelligence and orbital surveillance technologies could address maritime domain awareness gaps in Southeast A…
Read a full sample brief →UKDI launches Project PANOPTES competition seeking integrated counter-drone force-protection capabilities with £5 million available
UK Defence Innovation published Project PANOPTES on 3 September 2026, a Ministry of Defence-backed Themed Competition seeking integrated counter-uncrewed aerial system force-protection capabilities. Stage 1 submissions c…
Read a full sample brief →ASPI Fault Lines edition covers South Korean exercises, Paracel Islands construction, and Pacific Islands Forum tensions
The Australian Strategic Policy Institute published its fortnightly Fault Lines security monitor on September 2, 2026, covering August 21 to September 3, 2026. The edition addresses regional order developments including …
Read a full sample brief →UKDI launches Project PANOPTES competition seeking integrated counter-drone force-protection solutions with £5 million available
UK Defence Innovation launched Project PANOPTES on 2 September 2026, a Themed Competition run on behalf of the Ministry of Defence seeking integrated counter-uncrewed aerial system force-protection capabilities. Stage 1 …
Read a full sample brief →ASPI commentary flags National Cabinet data centre siting gap as unresolved policy question
The Australian Strategic Policy Institute published commentary on September 2, 2026 finding that National Cabinet addressed data centre power sourcing but left siting policy unresolved. ASPI identifies the absence of a f…
Read a full sample brief →Australian Government awards Babcock Australia $129 million Anzac class frigate sustainment contract as Capability Life Cycle Manager
The Australian Government has awarded Babcock Australia a contract exceeding $129 million to sustain the Royal Australian Navy's Anzac class frigates. Announced on September 2, 2026, the contract appoints Babcock Austral…
Read a full sample brief →GAO sustains GSI Pacific protest over Navy NAVFAC elimination from competitive range
On September 1, 2026, the GAO issued a bid protest decision resolving GSI Pacific Inc.'s challenge to the Navy Facilities Engineering Command's elimination of the firm from a competitive range. The decision addresses whe…
Read a full sample brief →ASPI analysis calls for formal Australia-US bilateral Defence Guidelines under the ANZUS framework at its 75th anniversary
The Australian Strategic Policy Institute published a commentary on September 1, 2026 recommending that Australia and the United States develop bilateral Defence Guidelines to strengthen Australia's deterrence architectu…
Read a full sample brief →Taiwan's legislature authorizes drone program funding under hedgehog defense strategy amid U.S. pressure
Taiwan's Legislative Yuan has passed legislation authorizing funding for the government's drone acquisition and development program, with a deadline of August 31, 2026. The authorization supports President Lai Ching-te's…
Read a full sample brief →