Investigations

 

At Glotfelty PLLC, our attorneys are also former federal investigators who have led and supported complex investigations in the public and private sectors. Trained at the Federal Law Enforcement Training Center (FLETC) and within multiple federal Offices of the Inspector General, we bring first-hand experience conducting internal and federal investigations that meet federal quality, evidentiary, and procedural standards.

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Our federal investigations practice spans the full lifecycle of enforcement, from internal whistleblower complaints, Inspector General investigations, and False Claims Act and other Department of Justice enforcement actions.

 

Internal Investigations

 

Internal investigations may have high stakes and be deeply sensitive. Allegations may involve senior leadership, financial misconduct, retaliation, or ethical violations and can expose an organization to legal, operational, and reputational risk. Our firm helps clients address these matters discreetly and effectively. Our investigations are conducted under applicable attorney-client privileges, work-product doctrines, and strict confidentiality, providing additional security to our clients.

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We help ensure issues are identified, documented, and resolved before they escalate into enforcement actions, litigation, or public exposure. When internal complaints go unheard, the complainant may turn to outside avenues, such as the media, lawsuits, or government agencies. Unaddressed complaints may amplify your risks and undermine workplace trust.

Our value lies with our ability to not only investigate facts but to also analyze potential legal, compliance, and ethical implications. We provide both internal investigative services and legal counsel, tailored to the sensitivity and scope of each matter.

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Federal Investigations & Government Enforcement Actions

 

Our attorneys provide experienced counsel for managing and responding to federal investigations and other enforcement actions. We help clients strategically navigate interactions with Offices of the Inspector General, the Department of Justice, and other federal oversight bodies, ensuring compliance with federal requirements while minimizing disruption and risk exposure. We understand how investigators think, what evidence carries weight, and how to position clients for the best possible outcome.

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False Claims Act Investigations

 

The False Claims Act continues to be one of the federal government’s most powerful enforcement tools. In fiscal year 2024, the Department of Justice reported a record high of qui tams filed.[1] The Department of Justice also reported nearly $3 billion in recovery last year, including cases involving federal contracting and program frauds.[2]

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High-profile and successful recoveries drive increased awareness, scrutiny, and incentives for insiders to come forward – making proactive compliance and response strategies even more important than ever.  Many companies discount the risk of insider reporting until it is too late.

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When allegations or investigations do emerge, implementing a timely and well-structured response is critical for protecting your organization and minimizing potential liability. A robust compliance framework not only demonstrates good faith but also helps identify issues early, mitigate exposure, and maintain credibility with oversight bodies.

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We can help your organization with:

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• Strategic Responses: guiding clients through subpoenas, civil investigative demands (CIDs), and other Inspector General or Department of Justice inquiries. We help ensure complete, accurate, and timely responses to protect client interests and demonstrate cooperation.

• Investigations Defense: advising on defense strategies aimed at reducing enforcement risk, securing declinations to intervene in qui tams, or achieving case closures without government intervention or further actions.

• Parallel Internal Investigations: conducting privileged-internal reviews alongside government inquiries to identify root causes, mitigate exposure, and evidence proactive compliance efforts.

• Post-Resolution Compliance & Remediation: providing ongoing compliance guidance during investigations and after settlements, including risk assessments, corrective action plans, and integrity monitoring to prevent reoccurrence and reduce collateral litigation risks.

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AbilityOne Program Specific Investigations

 

At Glotfelty PLLC, we are proud to be the only law firm with a primary focus on the AbilityOne Program and its participating nonprofits. Our attorneys combine deep knowledge of federal procurement law with firsthand experience in the AbilityOne community. Federal contracting is complex in its own right but the AbilityOne Program adds another layer of unique requirements, exceptions, and compliance obligations. Even well-meaning nonprofits may find elements difficult to navigate and external stakeholders may misunderstand how significantly the Program can differ from traditional contracting or commercial marketplaces. Unfortunately, federal contracting set-asides, like the AbilityOne Program, can be ripe for misunderstandings, heightened scrutiny, or allegations to the Inspector General or False Claims Act qui tams.

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Communications with the government should always be taken seriously, especially within the highly regulated federal contracting and AbilityOne set-aside environments. When inquiries or investigations arise from the Commission, an Inspector General, or the Department of Justice, our firm can help AbilityOne nonprofits navigate the complexities of federal investigations within this unique space. We can help your nonprofit implement corrective actions, strengthen internal controls, and develop strategic defenses which mitigate risks while preserving credibility to oversight bodies.

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Voluntary or Mandatory Disclosures

 

When potential misconduct is identified, determining whether and how to disclose to the government can be one of the most consequential decisions an organization makes. The right approach can mitigate exposure, preserve relationships with oversight bodies or contracting activities, and even limit or prevent criminal or civil liability. The wrong approach, or failure to disclose, can significantly amplify risk. 

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Federal contractors are often subject to mandatory disclosure requirements under the Federal Acquisition Regulation 52.2023-13 or related procurement laws. Credible evidence of certain violations of criminal law, such as bribery or kickbacks, may require timely, written disclosure.

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Even when disclosure is not mandatory, there can be several advantages to voluntary self-disclosure, such as non-prosecution or reduced liability. In May of 2025, DOJ released updated and more favorable self-disclosure procedures.[3] DOJ’s Criminal Division may decline to prosecute a company for criminal conduct when the company self discloses, fully cooperates, timely and appropriately remediates the conduct, and when there are no serious or egregious aggravating factors.[4]  Similarly, the False Claims Act statute specifically provides opportunities for reduced damages when violations are timely disclosed and entities cooperate.[5] These policies and laws underscore the government’s inclination to reward proactive compliance and transparency.

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At Glotfelty PLLC, we guide our clients through the complex disclosure landscape, helping determine whether disclosure is mandatory or strategically beneficial. We strongly recommend that any disclosure is made through counsel to preserve applicable privileges, protect confidentiality, and ensure communications, facts, and legal issues are appropriately framed.

 

Contact Us

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Contact us to schedule a consultation and learn more on how Glotfelty PLLC can help your organization navigate investigations, strengthen compliance, and reduce legal risks.

 

 

 

Sources 

 

[1] U.S. Dept. of J., False Claims Act Settlements and Judgments Exceed $2.9B in Fiscal Year 2024, available at: https://www.justice.gov/archives/opa/pr/false-claims-act-settlements-and-judgments-exceed-29b-fiscal-year-2024

(providing key statistics on showing FY24 set a record high of qui tams, with over 979 filed. Since DOJ tracking began in 1987, roughly 17,000 qui tams have been filed. In FY24, DOJ recovered over 2.9 billion, with $2.4 billion coming from qui tams.).

[2] Id.

[3] Dept. of J 9-47.120 -Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy, (May 12, 2025) available at: https://www.justice.gov/d9/2025-05/revised_corporate_enforcement_policy_-_2025.05.11_-_final_with_flowchart_0.pdf

 [4] Dept. of J. Manual, 4-4.112 Guidelines for Taking Disclosure, Cooperation, and Remediation into Account in False Claims Act Matters, available at: https://www.justice.gov/jm/jm-4-4000-commercial-litigation#4-4.112.

[5] 31 U.S.C. § 3729(a)(2)(“If the court finds that— the person committing the violation of this subsection furnished officials of the United States responsible for investigating false claims violations with all information known to such person about the violation within 30 days after the date on which the defendant first obtained the information . . . . the court may assess not less than 2 times the amount of damages which the Government sustains because of the act of that person.”).

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