ABSTRACT

Every federal and state law enforcement investigator and agency, as well as investigators and their organizations in the private sector, that investigates contract and procurement fraud, collusion, or corruption has an obligation to also search for systemic weaknesses and deficiencies that caused or may have caused or contributed to any fraud, waste, and abuse, and to document their findings. Investigators, examiners, and others should be officially recognized and rewarded when they identify such weaknesses, deficiencies, waste, and/or abuse. Investigative agencies and organizations have their own policies and procedures regarding how to retire a closed investigative case file. The equivalent of a financial death sentence for many government contractors is to be banned from or excluded from government programs. In summary, once the investigation and adjudicative action has been completed, the investigator usually has some additional work to do before the case file can actually be retired.