![]() Department of Justice, Securities and Exchange Commission and the United States International Trade Commission. He assists in investigations and litigations that involve complex e-discovery issues and has represented clients in matters involving the U.S. ![]() Hastings also advises clients concerning best practices in e-discovery. Contractors enrolling a new entity should closely review these additional requirements to ensure that the registration can be completed without delay.Īlex Hastings advises clients across a broad range of government contracting issues, including advising clients in transactional matters involving government contractors and assisting defense contractors and pharmaceutical companies in securing and performing government contracts. Further, an entity must indicate in the letter whether it permits a third-party company administrator to access its SAM registration and, if so, identify the authorized third party. These requirements prescribe, among other things, that the notarized letter must be signed by an entity’s president, CEO, or other authorized individual and include template language certifying to the identity of the Entity Administrator. Although this new requirement appears straightforward on the surface, the Federal Service Desk has established detailed requirements for the contents of the letter. Although GSA has indicated it has or will reach out to impacted entities, contractors would be well advised to confirm independently the accuracy of their current SAM registration.Īdditionally, in an effort to prevent future fraudulent activity, GSA is now requiring that anyone seeking to register a new entity in SAM provide an original, signed, and notarized letter identifying the authorized Entity Administrator. GSA has advised impacted entities to validate their SAM registration and confirm their financial information. The announcement does not elaborate on the scope of potentially impacted entities or the amount of misdirected payments at issue. The GSA announcement suggests that fraudulent SAM accounts may have been used to divert certain federal payments to unauthorized bank accounts. Kevin Geiger, Senior Planner – 80 ex.GSA recently announced it is supporting an Inspector General investigation into alleged, third-party fraudulent activity in the System for Award Management (“SAM”).
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