Bagram Airbase: Hub of U.S. Influence or Den of Iniquity?
We have
previously noted a rash of corruption by
Government officials, both military and civilian, in Southwest Asia. To be sure, it takes two to tango—and for every corrupt
Government official there is a corrupt contractor or wannabe
contractor—but the shenanigans over at Bagram Airfield caught our attention. We perceive an inequitable distribution of iniquity, with Bagram seemingly receiving more than its
fair share of noteworthy corruption stories.
Bagram Airfield, as described by this article on Wikipedia, is a “militarized airport and housing complex”
that was once an important Soviet military base and is now an important
U.S. military base. Home of the Theater Internment Facility, the
Airfield also has two runways, three hangars, and numerous support
buildings. In addition, Wikipedia states that “there are more than 32
acres of ramp space and five aircraft dispersal areas, with a total of
over 110 revetments.” Secured by British and U.S. forces in December 2001, the
Airfield has grown from housing roughly 350 troops
to now housing at least 20,000 personnel. Though focused on supporting
air force missions, the base is run by a two-star Army General.
Bagram Airfield is
noted for, among other things, being home to Bagram Theater Internment Facility, the Heathe Craig Joint Theater Hospital, and a second internment
facility that nobody discusses. However, Bagram is becoming noted for other things as well, such as traffic jams, sexual
assaults by military personnel and general
corruption. As of the
date of this writing, the Wikipedia article on Bagram includes three links to stories of corruption at Bagram (unrelated to allegations of
prisoner abuse at the internment facilities). We
noted one of the stories in a prior article—here.
Is Bagram just another military base, with the number of corrupt
fraudsters simply in proportion to its overall population? Or is it
something more—perhaps a poster child for failed leadership and
ineffective oversight and missing controls. Time may tell, but until
then all we have are news stories and press releases from the Department
of Justice, like this one.
On June 9, 2010, the DoJ announced that “two military
officials, two contractors, and [a] contracting company” were indicted
for “alleged roles in bribery and money laundering” related to “award of
a DOD trucking services contract in Afghanistan.” The two military
officials involved—retired U.S. Army Sergeant Charles Finch (now
residing in Hawaii) and 1st Sgt. Gary
Canteen (of Delaware)—were assigned to Bagram Airfield at the time.
The DOJ
press release reported that—
According to an indictment … retired U.S. Army Sgt. Charles O. Finch … accepted a $50,000 bribe in the fall of 2004 to influence the
award of a DOD trucking contract to AZ Corporation, an Afghan
contracting company. The indictment alleges that the owners of AZ
Corporation, brothers Assad John Ramin, 40, and Tahir Ramin,
32, both of Pennsylvania, offered the bribe to Finch. According to the
indictment, the bribe was paid through the business account of Finch’s
roommate at Bagram, 1st Sgt. Gary M. Canteen … to disguise the nature and source of the payment. Canteen
allegedly passed on a portion of the funds to Finch. According to the
indictment, shortly after the money was delivered to Canteen, Finch
recommended the award of the contract to AZ Corporation, which was
awarded the contract.
Finch, John Ramin, Tahir Ramin and AZ Corporation are each charged
with one count of conspiracy to commit bribery, one count of bribery,
one count of conspiracy to launder money and one count of money
laundering. Canteen is charged with one count of conspiracy to commit
bribery, one count of conspiracy to launder money and one count of money
laundering.
Each individual faces a maximum sentence of 15 years in prison
and a fine of $250,000 or three times the value of the bribe for the
bribery charge; a maximum of five years in prison and a fine of $250,000
for the bribery conspiracy charge; and a maximum of 20 years in prison
and a fine of $500,000 or twice the value of the laundered funds for
each of the money laundering and money laundering conspiracy charges. AZ
Corporation faces a fine of up to $500,000 for the bribery and
conspiracy charges and $500,000 for the money laundering and money
laundering conspiracy charges. The maximum fine could be increased to
twice the gain derived from the crimes or twice the loss suffered by the
victims of the crimes if either of those amounts is greater than the
statutory maximum fine.
You may
have heard of the contractor—AZ Corporation—before. The DoJ announcement notes—
John Ramin, Tahir Ramin and AZ Corporation were also charged in August 2008 and June
2009 … with bribery,
conspiracy to commit bribery and mail fraud related to the procurement
and delivery of concrete bunkers and barriers at Bagram Airfield. John Ramin, Tahir Ramin and AZ Corporation are scheduled to begin trial on these
charges on Aug. 16, 2010. Three former military officials have pleaded
guilty … to receiving bribes
from the Ramins and AZ
Corporation.
“Inherently Governmental”
On March 31, 2010, the Office of Federal Procurement Policy
(OFPP) issued a “notice of proposed policy
letter … to provide guidance to Executive Departments and agencies on
circumstances when work must be reserved for performance by Federal
government employees.” Comments on the proposed
policy letter were due June 1. The OFPP notice
referenced a March 4, 2009 Presidential Memorandum that requires the OMB “to clarify when governmental
outsourcing of services is, and is not, appropriate ….” The OFPP notice
also referenced § 321 of the FY 2009
National Defense Appropriation Act (Pub. Law
110-417), which required OMB to—
(i)
create a single definition for the term ``inherently governmental
function'' that addresses any deficiencies in the existing definitions
and reasonably applies to all agencies; (ii) establish criteria to be
used by agencies to identify ``critical'' functions and positions that
should only be performed by federal employees; and (iii) provide
guidance to improve internal agency management of functions that are
inherently governmental or critical.
According
to this story (written by Robert Brodsky)
at GovExec.com—
The notice also instructs
officials to avoid an overreliance on contractors for functions that are
‘closely associated with
inherently governmental’ or
that are ‘critical’ for the agency's mission. Agencies
with more than 100 employees would be required to develop new procedures
and training and to designate a senior official accountable for
implementing the changes.
The
proposal spells out 20 examples of inherently governmental activities
including awarding and administering contracts, determining budget
priorities and hiring or firing federal employees.
OFPP also would create a test to determine if
other functions meet the definition of inherently governmental. Agencies
would be asked to evaluate whether the function would commit the
government to a course of action or if sovereign power is involved.
The document lists 19 examples of functions
closely associated with inherently governmental work that require
additional oversight but which are not statutorily prohibited from
outsourcing. They include evaluating another contractor's performance,
assisting in contract management and any situation that might permit
access to confidential business information.
If an agency wants to use a contractor for any of these
functions, it must first establish guidelines in the contract regarding
specified ranges of acceptable decisions; assign an adequate number of
qualified federal employees to administer the work and take steps to
mitigate conflicts of interest, the policy letter states.
The guidance also requires greater supervision
of ‘critical’ functions, which are defined as jobs in
which at least a portion of the work ‘must be reserved to federal employees in order to ensure the
agency has sufficient internal capability to effectively perform and
maintain control of its mission and operations.’
Finally, we should note that FAR 7.5 addresses this topic by providing
“policies and procedures to ensure that inherently governmental
functions are not performed by contractors.”
So now that we have some background, let’s look at some of the
comments OFPP received. As Mr. Brodsky noted in his recent article at GovExec.com, “more than 100 individuals and organizations …
offered public comments” on the proposed
rule changes. As the article reported, “little consensus” was evidenced
by the comments.
We’re not going to recap the
comments; they can be found at the link above. But here are a few choice ones to give you some of the flavor—
- OMB Watch, a “nonprofit research and advocacy
organization,” teamed with CREDO Action to turn in a petition with more than 29,000 signatures.
According to this article, “Commenters
urged the government not to allow security contractors to perform
functions like ‘guard
services, convoy security services, pass and identification services,
plant protection services, the operation of prison or detention
facilities, and any security operations that might reasonably require
the use of deadly force.’
They also asked OFPP to prevent contractors from performing ‘support of intelligence activities
(including covert operations), interrogation, military and police
training, and the repair and maintenance of weapon systems.’
- The Small Business Administration (SBA) wrote that it was concerned about the impact of the proposed
rule(s) on small businesses. The SBA stated, “The net result of this
policy should not be a reduction in the percentage of contracts awarded
to small businesses.”
- The Council of Defense and Space Industry
Associations (CODSIA) stated that it was generally supportive of the
rule. However, CODSIA stated, “We are particularly concerned that the underlying adversarial
tone of the proposed policy is one which calls for the government to be
vigilant in order to guard against contractor attempts to overtake
portions of the government‘s mission. We find this language to be
counter-productive and would suggest that this proposed policy contain
explicit language emphasizing the government/industry partnership,
particularly for functions that are not inherently governmental, and our
mutual interest in conducting the public‘s business in as cost
effective a manner as possible.”
This is kind of a big deal, because
many contractors generate a large portion of their sales from providing
services to the Federal government. For the past 15 years or so, policy
in this area has been based on the notion that “privatizing” government
operations will lead to operational efficiencies and commensurate cost
reductions. Some critics have charged that the trend toward
privatization went too far, such that the government lost critical
skills and knowhow. The Obama Administration has expressed its interest
in reversing that trend, and has introduced the concept of “insourcing.”
We don’t necessarily have a dog in
this hunt, but we do note two interesting studies that would seem to
bear on the situation. First, in this previous
article we discussed a recent GAO study that
compared use by the State Department of private contractors versus
government employees to provide security services. The GAO study
concluded that using government employees was more than 10 times more
expensive than using contractor personnel on
three of four contract scenarios it evaluated. (In the fourth scenario,
the savings was much less, but it was still there.) In the upcoming
era of tight Federal budgets, one ignores that kind of math at one’s own
peril.
Second, we also reported on a recent blog post by Dr. Loren Thompson of the Lexington
Institute, in which he expressed a “contrarian” viewpoint regarding
commonly held acquisition reform myths. We wrote—
Adding more acquisition, audit, and program
management professionals to DoD’s ranks won’t solve the myriad problems with the Pentagon’s
acquisition process, but it will compound the problem. We are all familiar with the lack of
Government resources in this area, and the current reliance on
contractors to augment short-staffed contracting offices. But Dr. Thompson notes that those new
heads will take additional funds—not just to cover the costs of salary
and benefits, but also to cover the costs of training, equipping,
housing and supporting them.
As Dr. Thompson notes, ‘When you add up all these costs, the long-term
burden of taking on 20,000 new acquisition professionals will be over
$80 billion -- which just happens to be the projected cost of buying a
replacement for the Trident ballistic-missile sub.’
In other words, “insourcing” might make for great press and keep certain interests happy,
but it also carries with it tremendous budgetary impact, as well as a
potential impact to many current Federal contractors.
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CWC Assesses “System for Curbing Contract Waste, Fraud, and Abuse”
It’s rarely dull when the Commission on Wartime Contracting in
Iraq and Afghanistan (CWC) holds a hearing. Our past stories have
included—
- “New Report Blasts DOD Management
of Contractors Deployed on the Battlefield”
- “Testimony Blaming Contractor Internal Controls”
- “CWC – Out of Touch with Reality?”
- “DOD Responds to CWC’s Concerns”
On May 24, 2010, the Commission was back at its oversight job,
this time evaluating “the challenges and
issues that confront law-enforcement officials as they attempt to
discover and successfully prosecute fraud in a contingency environment,”
and also hearing about “the work of the Inspectors General for USAID,
State, and Defense” regarding their efforts to combat the unholy trinity
of waste, fraud, and abuse in the Southwest Asia (SWA) theater of
operations. This was a follow-up hearing to one
held in February, 2009.
Co-Chair Shays opened the hearing by saying—
Testimony at that first hearing established
that billions of taxpayer dollars have been lost to waste, fraud, and
abuse. The inspectors general
told us that contributing causes included: … insufficient numbers of
adequately trained contract officers and auditors, poorly written
contracts with haphazard record keeping … as the DoD witness put it, ‘continual exposure to offers of bribes,
gratuities, and kickbacks.’
In
his discussion of fraud, Mr. Shays was careful to be evenhanded. He
said—
Let me emphasize that our outrage is
not directed solely at misbehaving contractor employees. More than a
third of the 477 subjects of open investigations tabulated by the
International Contract Corruption Task Force in May were U.S. government
employees or military personnel. … [Therefore] [w]e are particularly interested in seeing expanded
anti-fraud initiatives and actions, unity of effort among federal
agencies, recognition that many peacetime ways do not work in wartime,
balancing between accelerated contracting and appropriate safeguards,
and greater accountability.
The
first panel included several government investigators. They discussed
various topics, including the International Contract Corruption Task
Force (ICCTF), which is an outgrowth of the National Procurement Fraud Task Force. For example, James Burch (Department of Defense Office of Inspector General, Deputy
Inspector General for Investigations) testified—
Contract
administrators focused primarily on timely mission accomplishment versus
ensuring strict adherence to traditional contract administration
procedures, many of which are designed to reduce the risk of corruption
and abuse. When engaging in contingency contracting, administrators
typically do not consider the risk of increased levels of fraud
resulting from lower levels of oversight, as the mission is to provide
goods and services as promptly as possible. When left unchecked, this
mind set can become pervasive to the extent contract administrators
begin to view oversight responsibilities as unwelcome burdens conflicting with their ability to effectively perform
their duties. This factor has been especially prevalent when exploring
allegations of corruption and abuse related to funds administered via
the Commander’s Emergency Response Program (CERP), which was designed to
fund development of local programs and institutions.
He
also testified that “As of May 1, 2010,
106 DCIS agents (approximately 33% of the DCIS workforce) are involved
in investigating a total of 223 Overseas Contingency Operations (OCO)
cases. The volume of criminal cases has increased by roughly 18 percent
over the past year.”
Mr.
Kevin Perkins (Assistant Director, Criminal
Investigative Division, Federal Bureau of Investigation) testified
that—
Since 2004, the
ICCTF has initiated nearly 700 investigations in Afghanistan, Iraq, and
Kuwait. To date for FY 2010, the ICCTF has 273 pending cases. Only seven
months into the fiscal year, the ICCTF has already generated 80% of the
prior year’s case load. In FY 2009 alone, the ICCTF obtained over $3.3
million in forfeitures/seizures, over $1 million in fines/penalties, and
over $1.1 million in restitution. To date in FY 2010, the ICCTF has
obtained over $47 million in restitution, and $1 million in
forfeitures/seizures.
The CWC also heard from
SIGAR (Special Inspector General for Afghanistan Reconstruction, which
is a parallel organization to SIGIR, who also provided a representative to testify before the CWC). They heard that “SIGAR currently has 42 pending investigative matters, 57
percent of which are focused primarily on contract and procurement
fraud, 31 percent on corruption, and the remainder on theft of
government property.”
Here is a link to a two-and-a-half-hour long
C-SPAN video of the first Panel.
As
noted above, the second panel was all about the various Inspectors
General. The IG for the USAID testified that the agency had found “poor contract and
program management practices.” He also told the CWC that—
From February 2009 to date, we have issued 12
performance audits with 84 recommendations for USAID improvement and
completed 19 financial audits that identified $206 million in questioned
costs, of which $180 million were sustained. Over the same term, we
opened 43 civil and criminal investigations, closed 17 investigations, effected 10 arrests and 3 convictions, and secured $141 million in
investigative savings and recoveries for the Government.
The
USAID Inspector General also testified that—
We cannot measure the full extent of waste, fraud, and
abuse in Iraq and Afghanistan but can provide information on what we
have found. From 2003 to the present, we have submitted $4.9 billion of
the $17 billion USAID has obligated in Iraq and Afghanistan to
in-country financial audits. These audits questioned $282 million in
costs, or approximately 6 percent of the total audited. Over that
period, we identified an additional $166 million in waste, fraud, and
abuse in USAID’s Iraq and Afghanistan program portfolio in the form of
investigative savings and recoveries.
Last year, the
amount of waste, fraud, and abuse that we identified increased. Thus
far, our FY 2009 investigative leads and referrals have led to $101
million in investigative savings and recoveries—more than all of our
leads and referrals from FY 2003 to 2008 combined. A similar pattern
emerged with our audits, as the percentage of questioned costs arising
from in-country financial audits increased in FY 2009. This increase in
observed waste, fraud, and abuse is primarily associated with a small
number of contracts with a few firms, but some of it may result from the
growing prevalence of contract and program management issues we have
witnessed during our performance audits.
The
Department of State Deputy Inspector General told the CWC that his team
found “an insufficient number of U.S.
Government contracting personnel in the field, which led to weak
oversight and management of programs. This situation is a root cause of
poor ‘ground truth’ monitoring of contractors, incomplete contract
files, and untimely or inadequate review of invoices.”
The
DOD Deputy Inspector General for Auditing told the
CWC about “10 systemic issues related to deficiencies in the contract
management process.” The 10 areas of concern were: “requirements, contract documentation, contract type, source
selection, contract pricing, oversight and surveillance, inherently
governmental functions, property accountability, award fees, and
financial management.”
Here is a link to a two-and-a-half-hour long C-SPAN video of the second Panel.
ANC May Not Qualify for 8(a) Status
By operation of statute, Alaska Native Corporations (ANCs) enjoy preferential treatment in government contracting. Such firms receive special rights under the Small Business
Administration’s (SBA) “8(a)” program. Under the 8(a) program, ANCs can
receive sole source awards, regardless of dollar value, with no upper
limit. In contrast, other 8(a) firms are prohibited from receiving sole
source awards valued at more than $3 million. (See 13 C.F.R. 124.506(b).)
Sole-source procurements to tribes and ANC owned 8(a) firms may not be
protested, because there is no injured party. Moreover, a DOD
contractor that subcontracts with an ANC is
entitled to receive a “bonus” equal to 5 percent of the value of the
subcontract award.
As one analysis notes—
The
Justice Department has determined that tribal and ANC-owned 8(a) firms are not subject to the U. S. Supreme Court’s ruling in the Adarand case. As set out in the
Justice Department’s proposed policy, issued in the May 23, 1996 Federal Register, any
limitations that may end up being imposed on the
SDB and 8(a) programs as a result of Adarand will not be applicable to tribal and
ANC-owned 8(a) firms. This is because the tribes and ANC are included in the 8(a) and the SDB programs as a result of their
unique government to-government relationship with
the United States, not because of race or national origin factors.
As can
be seen from the foregoing, in the competitive world of Federal
contracting, being an ANC is a huge competitive advantage—so much so,
that observers began to grow concerned that the ANCs had too much of an
advantage. For example, as this article
reported that “No-bid contracts awarded to ANCs ballooned from $508.4
million in 2000 to $5.2 billion in 2008....” It also noted that a 2006
GAO report “called the ANC loophole ‘an open checkbook’ for the
companies.” The article also discussed the “complex business
partnerships” that ANCs sometimes form with other “firms that have no
ties to the SBA program or Alaska” in order to
perform the contracts they win. Finally, the
article quotes Senator Claire McCaskill (D-MO) as saying, “Nobody begrudges giving small,
disadvantaged businesses a chance to win federal contracts. But the
Alaska Native Corporations have used their special preference to bust
the door down.”
Recently, the SBA Inspector General has questioned
the bona fides of one ANC, Alaska Native
Technologies LLC (ANT), suggesting that the company (a participant in the 8(a) program) “is not owned and
controlled by its disadvantaged owner, and that ANT non-disadvantaged
business owner has other business interests that conflict with his
managerial duties at ANT.” The SBA OIG report can be found here.
The OIG report discusses the formation of ANT, and
stated—
ANT was formed in January
2003 by Patrick Simpson, a non-disadvantaged individual, as a spin-off
division of his research and development company (Scientific Fishery
Systems, Inc.) for his defense contract business. ANT is 51-percent
owned by the Native Village of Eyak through its holding company, Alaska Native General
Services, LLC (ANGS) and 49-percent owned
by Skookum
Technologies, Inc.-another business for which Mr. Simpson is the
majority owner.
Our review identified irregularities
regarding the formation of ANT, indicating that Patrick Simpson, the
non-disadvantaged owner of Skookum, may be controlling ANT and operating it for the
benefit of his defense contract business. Mr. Simpson also entered into
multiple business arrangements that allowed him to capitalize on the
firm's 8(a) status and to profit through services performed for ANT by
other companies that he owned. Further, Mr. Simpson was involved in
managing the day-to-day activities of ANT and, through management
services performed by Skookum for ANT, had control over the payment of invoices that
were billed to ANT by other companies he owned. Consequently, DCAA
identified irregularities in fees invoiced and paid by Skookum.
As
usual, Robert Brodsky at GovExec.com was all over the issue, nicely summarizing some of the OIG’s findings. Some of those findings included—
- ANT
was formed with no tangible assets and with no cash on its books.
Instead, the firm was established with … goodwill that was transferred
to ANT by Skookum and ANGS. Annual audited financial statements for ANT
prepared from October 2003 to September 2008 do not reflect the …
goodwill used to establish ANT.
- Although ANGS
purchased … goodwill from Skookum that it then transferred to ANT, the purchase was made
without any exchange of funds. Instead, ANGS agreed to pay Skookum … from its share
of the future profits of ANT. Skookum provisionally forgave ANGS' debt on the same day that
the … debt was incurred. The two parties agreed that if ANT was dissolved with any amount of … debt
outstanding, ANGS would not owe Skookum anything further, regardless of the actual debt
balance.
- The financial statements of ANT do not recognize
the shared ownership arrangement between Skookum and ANGS. … Further, ANT's 2007 financial statements reported a
related party transaction between ANGS and ANT, which should not have
been classified in this manner if ANGS was an owner. According to
Generally Accepted Accounting Principles, distributions to owners reduce
their respective capital accounts, and therefore, are not treated as
related party transactions that are expensed against operations.
- Evidence suggests that the
disadvantaged owner, Alaska Native General Services, may no longer
exist. … a
search of the Alaska State Corporations' website showed that Alaska
Native General Services had not made biennial filings with the Alaska
Department of Commerce since November 9, 2005. Finally, the Federal
Employer Identification Number (FEIN) 02-0653329 provided to SBA for tax
verification of Alaska Native Government Services … could not be
located in the FEIN database, which contains more than 12 million
numbers. The data base contained no records for either Alaska Native
Government Services or Alaska Native General Services.
- Although SBA approved a business partner of Mr. Simpson
as the General Manager of ANT, it appears that Mr. Simpson was heavily
involved in managing the day-to-day activities of ANT. ANT stated that
Mr. Simpson was its Director due to company oversight responsibilities
passed onto Mr. Simpson by the Village of Eyak. Further, DCAA's review of 1,500 of Mr. Simpson's
emails showed that he was involved with employee clearances, timecards,
and other operational issues, which are consistent with performing as a
Director. Mr. Simpson obligated ANT to lease payments by signing leases
for office space as either its "President," "Director," or "member."
Mr. Simpson signed ANT's tax returns as "President" or "Director."
Although non-disadvantaged individuals are allowed to provide management
services to a tribally-owned concern with SBA's approval, such an
approval was not sought from or granted by SBA for Mr. Simpson.
- In addition to his Director role at ANT, Mr.
Simpson is also the President of Scientific Fishery, and owner of RV
Montague, Skookum, PKS Consulting, Inc., P&P Properties, LLC, and
6100 A Street, LLC. Although members, directors, and officers of a
tribally-owned firm are precluded from having other business interests
that conflict with the management of the
concern, Mr. Simpson entered into business arrangements
with ANT on behalf of other companies that he owned.
- According
to ANT's audited financial statements, from October 2003 through
September 2008, Mr. Simpson:
o rented equipment to ANT through a company he
owned, called P&P Properties, LLC;
o rented office space to ANT through another one of
his companies, 6100 A Street;
o provided subcontracting services to ANT through his
company, Scientific Fishery;
o provided consulting services to ANT through his company,
PKS consulting;
o provided
professional services to ANT through his company, Skookum, including the
processing of payroll, accounts payable,
and accounts receivable;
o According to DCAA, Mr. Simpson also leased the exclusive
use of his boat (the Research Vessel Montague) to ANT.
- [A]s majority owner of Skookum, Mr. Simpson was
in a position to process invoices sent to ANT by other companies he
owned that were performing work for ANT.
- In 2008, DCAA questioned the validity of$124,000 of
fees paid to PKS Consulting for consulting services supposedly provided
to ANT on one contract. Mr. Simpson's FY 2006 average of 140 hours of
consulting services per month on this cost-type contract may have been
excessive as Mr. Simpson had little time to perform these services,
given his role as ANT Director, President of Scientific Fishery, and as
owner of RV Montague and Skookum. DCAA also reported a lack of documentation supporting
these fees. Further, Mr. Simpson appeared to be managing the day-to-day
activities of ANT that were unrelated to providing ANT with systems
engineering expertise.
Based on the
foregoing, the SBA OIG concluded that “it appears that ANT’s primary
purpose is to benefit Mr. Simpson …”
What
might be the outcome if the SBA confirms that ANT did not qualify as a ANC participant in the
8(a) program? Well, we’re not sure. But we remember a contractor who was
fined for falsely reporting socioeconomic awards, and another contractor
who was fined for falsely certifying that it had implemented controls to
detect and prevent violations of its business conduct policy.
Consequently, we expect Mr. Simpson to face significant monetary
penalties if he is convicted of making false statements with respect to
ANC’s qualifications to participate in the 8(a) program.
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