Sheila A. Armstrong

Clients turn to Sheila for her knowledge of developing and maintaining corporate compliance programs. In this area, she conducts compliance reviews, training, and internal investigations, and advises clients on required disclosures under the Federal Acquisition Regulation (FAR) and 2 CFR Part 200. She has represented clients before defense and civilization agencies, including the US Department of Justice (DOJ), the General Accountability Office (GAO), the US Department of Defense (DoD), the GSA, and various Suspension and Debarment Officials.

Complementing her contracting work, Sheila provides counsel on foreign sourcing issues and regularly advises on compliance with the Buy American Act, Trade Agreements Act, and other foreign sourcing restrictions applicable to federal contracts.

Sheila is an active member of the American Bar Association’s Public Contracts Law Section, serving in a leadership role as council member, co-chair of the Procurement Division, vice chair of Finance, and vice chair of the Commercial Products and Services Committee. She frequently assists with comment letters submitted on behalf of the American Bar Association relating to new and updated regulatory changes.

• A leading software provider in a referral from the GSA Office of Inspector General to the DOJ for allegations relating to providing unqualified personnel and underreporting contract sales
• A client in CNCS Office of Inspector General investigation resulting from a self disclosure of potential improper use of grant funds
• A defense contractor in a DoD Office of Inspector General disclosure and associated investigation by the US Army Criminal Investigation Command (CID) resulting from first article test failure of defense product at an Army testing lab.  Resulted in repair of prior products delivered but no monetary penalty
• A leading services contractor in a referral from the Library of Congress Inspector General to the DOJ for allegations relating to providing unqualified personnel
• A leading technology company in a qui tam action relating to noncompliance with GSA contract requirements
• A client in a DoD investigation and follow-on referral to the DOJ resulting from alleged defective products delivered to various branches of the military
• Conducted numerous investigations relating to potential noncompliance with GSA contract requirements, including commercial sales practice disclosures, Price Reductions Clause compliance, and potential overcharging
• Numerous companies in mandatory disclosures at the DoD, GSA, and other agencies
• Numerous companies in audits, investigations, and qui tam matters relating to alleged noncompliance with foreign sourcing requirements including the Buy American Act and Trade Agreements Act
• Numerous companies in pre-award and post-award GSA Office of Inspector General audits
• Numerous companies in presentations to Suspension and Debarment Officials for the US Army, US Air Force, US Navy, and General Services Administration, among others
• Conducted several investigations related to internal whistleblower/hotline complaints
• Conducted many compliance reviews to assess internal controls, policies, and procedures relating to government contracts
• Routinely provide advice in due diligence related to acquisitions and divestitures of government contractors