Government contractors can be forgiven if they feel like they’re stuck in the middle when it comes to compliance.  On one side are a full range of government resources including IG offices, DCAA, the Departments of Labor and Justice, and more.  Justice’s marquis compliance program is the Procurement Collusion Strike Force, the name of which should make clear the agency’s aggressive compliance stance.  As of June, the Strike Force had over 28,000 agents and 90+ open investigations.  The Strike Force website states that DOJ has secured 46 guilty pleas or convictions and recovered over $50 million.  The main focus areas are anti-trust, collusion, and price fixing.  On the other side are whistleblowers, typically former employees or competitors who can benefit financially from any recovery.  That’s a powerful incentive for many people and there are scores of attorneys promoting their qui tam experience who are ready to help.  A quick Google search on “Qui Tam Whistleblower” shows that 18 of the top 20 results are plaintiff’s attorneys just waiting to make filing a new qui tam suit fast and easy.  In fact, most contractors may be more prone to a whistleblower case than a government audit based on the sheer number of private sector resources.  Fun fact:  Even when the government wants to settle a qui tam case, the whistleblower may resist if they feel that the settlement amount is insufficient.  Audits, investigations, and whistleblower cases can literally cost millions of dollars to defend against, not to mention lost productivity and even the loss of key people.  Contractors must ensure that they have sound, reliable contract compliance processes.  While some may look on such expenses as “overhead”, it’s better to have that then be “under” the gun in the event of an audit or lawsuit.