Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Todd R. Steggerda

Photo of Todd R. Steggerda Todd Steggerda serves as McGuireWoods’ Deputy Managing Partner for Strategic Development, following service as the deputy managing partner for litigation where he oversaw and managed the firm’s litigation departments and roughly 500 litigators in the U.S. and the UK. He is the former chair of the firm’s Government Investigations and White Collar Litigation Department, which Law360 recently selected for its prestigious “Practice Group of the Year” award. In a dynamic practice spanning nearly 25 years in Washington, Todd has resolved a diverse range of high-stakes government investigations, regulatory enforcement, and litigation matters, including dozens of matters investigated by the civil and criminal divisions of the Department of Justice, the Department of Defense, and numerous other federal and state agencies and investigative bodies.

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Department of Defense Issues Final Rule on Cybersecurity Standards for Contractors

By Edwin O. Childs, Andrew Konia, Abram J. Pafford, Todd R. Steggerda, Jack White, James Dougherty, Jason M. Vespoli, Maura Naehr, John Sullivan and Sophie Marsh on Government Contracts
After years of waiting, the U.S. Department of Defense (DoD) posted to the Federal Register for public inspection on September 9, 2025, a final rule implementing the Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0) standards into the Defense Federal Acquisition Regulation Supplement (DFARS) (the Final Rule), which was formally published a day later on September… Continue Reading

California Defense Contractor and Private Equity Firm Agree to Pay $1.75M to Resolve False Claims Act Liability Relating to Voluntary Self-Disclosure of Cybersecurity Violations

By Todd R. Steggerda, Edwin O. Childs, Michael J. Podberesky, Abram J. Pafford, Brett Barnett, Jack White, Andrew Konia, Jason M. Vespoli, Maura Naehr and John Sullivan on Fraud, Deception and False Claims
On July 31, 2025, the U.S. Department of Justice  (“DOJ”) announced a $1.75 million False Claims Act (“FCA”) settlement with Aero Turbine Inc. (“Aero Turbine”), a California-based defense contractor, and private equity firm Gallant Capital Partners LLC (“Gallant Capital”).  The settlement arises out of allegations that Aero Turbine failed to comply with certain cybersecurity requirements… Continue Reading

Supreme Court Declines to Narrow Reach of Federal Fraud Law

By Brett Barnett, Edwin O. Childs, John S. Moran, Abram J. Pafford, Michael J. Podberesky, Todd R. Steggerda, Jack White, Michael A. Brody, Maura Naehr, John Sullivan and Jason M. Vespoli on Fraud, Deception and False Claims, Government Contracts
On May 22, 2025, the Supreme Court published its opinion in Kousisis v. United States, No. 23-909, 605 U.S. __ (2025), holding that one who induces a victim to enter into a transaction under materially false pretenses may be convicted of federal fraud even without the intent to cause the victim economic loss. In a… Continue Reading

Department of Justice Suggests “Aggressive” Enforcement of False Claims Act

By Edwin O. Childs, Brett Barnett, Jack White, Farnaz Farkish Thompson, Michael J. Podberesky, Todd R. Steggerda, Jason M. Vespoli, John Sullivan and Maura Naehr on Compliance, Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims, Government Contracts
In a speech to the Federal Bar Association’s annual qui tam conference on Feb. 20, 2025, Michael Granston, Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice, discussed how the Trump administration plans to “aggressively” enforce the False Claims Act (FCA). His statements come on top of other comments from Trump… Continue Reading

“There are Cops on the Beat”: DOJ’s Procurement Collusion Strike Force Leader Emphasizes Criminal Antitrust as Top Enforcement Priority

By Amy Manning, J. Brent Justus, Holden Brooks, Angelo Russo, Todd R. Steggerda, Abram J. Pafford, Jack White, Edwin O. Childs, Laura Colombell Marshall, Brandon M. Santos, Casey Erin Lucier, Paul T. Atkinson, Evan Tucker, Colin F. Brady and Jordan LaPointe on Compliance
On September 14, 2023, Daniel W. Glad — Director of the Procurement Collusion Strike Force (“Strike Force”) for the Department of Justice’s (“DOJ”) Antitrust Division — gave remarks as the keynote speaker for the Virginia Bar Association’s Annual White-Collar Fall Forum, emphasizing a renewed commitment to pursuing criminal investigations in the federal procurement arena.  DOJ… Continue Reading

U.S. Supreme Court Clarifies DOJ’s Authority to Dismiss Whistleblowers’ False Claims Act Suits, Questions Constitutionality of Qui Tam Provisions

By Edwin O. Childs, Michael J. Podberesky, Jonathan Ellis, Gretchen Heinze Townshend, Todd R. Steggerda, Charles Wm. McIntyre and Jason M. Vespoli on Fraud, Deception and False Claims
The U.S. Supreme Court recently resolved a circuit split by holding that, in a False Claims Act action, (1) the government may seek dismissal of a qui tam case in which the government initially declined to intervene over the relator’s objection so long as it later intervened in the litigation, and (2) district courts should… Continue Reading

DOJ and Aerojet Settle for $9 Million in Qui Tam Cybersecurity False Claims Act Case

By Edwin O. Childs, Todd R. Steggerda, Abram J. Pafford, Andrew Konia and Jason M. Vespoli on Fraud, Deception and False Claims, Government Contracts
On July 8, 2022, the U.S. Department of Justice announced a $9 million settlement with federal government contractor Aerojet Rocketdyne, Inc. for alleged violations of the False Claims Act in a case pending in the Eastern District of California. The settlement results from alleged false statements by Aerojet related to compliance with Department of Defense… Continue Reading

Largest-Ever Small-Business Contracting Fraud Settlement Related to Pass-Through Subcontracting

By Edwin O. Childs, Michael J. Podberesky, Todd R. Steggerda and Jason M. Vespoli on Enforcement and Prosecution Policy and Trends, Government Contracts
Federal contractors should take note of a $48.5 million False Claims Act settlement between the Department of Justice and TriMark USA LLC — the largest-ever FCA settlement based on allegations of small-business set-aside contracting fraud. DOJ alleged that TriMark had a plan to circumvent specific small-business contracting requirements by providing significant assistance to three small… Continue Reading

DOJ Settles First False Claims Act Enforcement Action Since Launch of Civil Cyber-Fraud Initiative

By Edwin O. Childs, Todd R. Steggerda, Laura Colombell Marshall, Charles Wm. McIntyre, Michael J. Podberesky, Andrew Konia and Jason M. Vespoli on Fraud, Deception and False Claims
On March 8, 2022, the U.S. Department of Justice (DOJ) announced a $930,000 settlement with Comprehensive Health Services, LLC (CHS) for alleged violations of the False Claims Act (FCA). This settlement marks DOJ’s first resolution of an FCA enforcement action involving cyber fraud after launching its Civil Cyber-Fraud Initiative in October 2021, signaling DOJ’s eagerness to combat cybersecurity violations… Continue Reading

Biden Administration Amends “Buy American” Rules to Increase Domestic Content Requirements

By Edwin O. Childs, Alex J. Brackett, Abram J. Pafford, Jack White, Todd R. Steggerda and Jason M. Vespoli on Enforcement and Prosecution Policy and Trends
On March 7, the Federal Acquisition Regulatory Council promulgated a final rule aimed at increasing federal government preferences for goods and construction materials that are domestically manufactured and increasing the required domestic content threshold for purchases governed by the Buy American Act. Read on for highlights from the rule and next steps for government contractors… Continue Reading

CMMC 2.0: Department of Defense Revamps Cybersecurity Maturity Model Certification Program

By Edwin O. Childs, Abram J. Pafford, Todd R. Steggerda and Jason M. Vespoli on Government Contracts
On November 4, 2021, the Department of Defense (DoD) announced significant changes to the strategic direction of the Cybersecurity Maturity Model Certification (CMMC) program.  Specifically, DoD stated that the goal of these changes is to simplify the CMMC standard and prioritize the protection of certain types of controlled defense information.  After a nine-month internal review by the… Continue Reading

Corporate Campaign Contributions Are a Crime, Independent Expenditures Legitimate: Sixth Circuit Explains the Difference

By Simon Davidson and Todd R. Steggerda on Enforcement and Prosecution Policy and Trends, Government Contracts
The Sixth Circuit has upheld the felony conviction of a former state party chair for illegal campaign contributions by a corporation he owned, in a case that both serves as an important reminder of the prohibition on corporate contributions to federal campaigns and shows that the Justice Department may be stepping up criminal election law… Continue Reading

Tide Is Turning Against FCA Case Dismissals

By Michael J. Podberesky, John S. Moran, Todd R. Steggerda, David Pivnick and Cassandra M. Burns on Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
According to a July 28 article in Law360 by McGuireWoods lawyers Michael J. Podberesky, John S. Moran, Todd R. Steggerda, David Pivnick and Cassandra M. Burns, the U.S. Supreme Court’s recent decision declining to review an appeal of a Seventh Circuit case that could have resolved a three-way circuit split regarding the proper standard for… Continue Reading

President Biden Announces Findings of Critical Supply Chain Assessment

By Edwin O. Childs, Abram J. Pafford, Todd R. Steggerda and Jason M. Vespoli on Government Contracts
On June 8, the White House released the findings of a 100-day assessment of critical supply chains, identifying actions needed to bolster domestic manufacturing of critical goods, reduce dependence on foreign nations for supply chain needs, create jobs and address unfair trade practices. For highlights of the report detailing structural weaknesses in supply chains for… Continue Reading

Biden Administration Orders $15 Minimum Wage for Federal Contractors

By Edwin O. Childs, David Greenspan, Abram J. Pafford, Todd R. Steggerda, Jason M. Vespoli and Daniel C. Masakayan on Government Contracts
On April 27, 2021, President Biden signed an Executive Order (EO) requiring federal contractors performing service, construction or concession contracts to pay a $15 minimum wage to those employees who are working on such contracts. As noted in the White House Fact Sheet, this EO will build on Executive Order 13658 (signed in February 2014), under which the government… Continue Reading

U.S. Supreme Court Declines to Clarify False Claims Act Falsity Standard

By Michael J. Podberesky, Todd R. Steggerda, David Pivnick, John S. Moran and Jason M. Vespoli on Fraud, Deception and False Claims, Government Contracts
The U.S. Supreme Court recently declined to address a circuit split regarding the standard for establishing that a statement material to a claim for payment is false under the False Claims Act (FCA); specifically, whether the FCA requires pleading and proof of an “objectively false statement,” or whether liability can be based on allegedly false… Continue Reading

Biden Administration Orders Comprehensive Review of U.S. Supply Chain

By Edwin O. Childs, Alex J. Brackett, Patrick Rowan, Abram J. Pafford, Todd R. Steggerda and Jason M. Vespoli on Government Contracts
On Feb. 24, 2021, President Joe Biden signed an executive order (EO) triggering a comprehensive review of U.S. supply chains, ordering agencies to identify ways to secure the American economy against shortages of critical and essential goods. As noted by the White House, this EO requires federal agencies to conduct a two-phase review of U.S. supply chains. First,… Continue Reading

Ask Those Questions: Federal Circuit Highlights Required Step for GAO Protesters Seeking Relaxed Automatic Stay Deadline in DOD Procurements

By Abram J. Pafford, Todd R. Steggerda and Edwin O. Childs on Government Contracts
Disappointed government contractors and their legal counsel weigh the benefits of filing bid protests at the Government Accountability Office (GAO) versus the Court of Federal Claims (COFC). One of the key benefits to filing a protest with the GAO is that, under the Competition in Contracting Act (CICA) automatic stay provision, a GAO protester who… Continue Reading

Congressional Investigations: A Month In, Congress Signals Close Scrutiny of CARES Act and Paycheck Protection Program

By Jeffrey M. Hanna, John Adams, Todd R. Steggerda and Mona G. Mohib on Compliance
The CARES Act is only a month old, but plans for investigations to track the nearly $3 trillion in coronavirus relief funds are already emerging from Congress. Among the mechanisms for oversight created and funded by the CARES Act itself is the Congressional Oversight Commission, a five-member committee overseeing $500 billion in loans doled out… Continue Reading

Positive FCA Enforcement Trend for Defense Contractors: DOJ Reaffirms Commitment to Exercise Statutory Authority to Dismiss

By Edwin O. Childs, Christina Egan and Todd R. Steggerda on Compliance
Following recent changes to Department of Justice policy regarding individual accountability in government investigations of corporate wrongdoing, DOJ has recently further demonstrated its willingness to consider a flexible approach in applying the False Claims Act. In a January 28, 2019 speech by Deputy Associate Attorney General Stephen Cox to the 2019 Advanced Forum on False Claims… Continue Reading

Congressional Investigations: Beyond Sensational Headlines — Incoming House Leaders Announce Broad Investigative Priorities Targeting Business Community

By John Adams, Ryan M. Bernstein, Robert J. Bittman, Louis D. Greenstein, Charles Wm. McIntyre, Mona G. Mohib, Patrick Rowan and Todd R. Steggerda on Election and Political Law, Enforcement and Prosecution Policy and Trends
In the politically explosive atmosphere of Washington, the talk of the town is focused on congressional investigations: who will be called before Congress, and when. Newspaper headlines blare the latest controversy — from use of personal emails for government business, to numerous investigations alleging corruption of current and former government employees, including several cabinet secretaries,… Continue Reading

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