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, 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 Department of Justice, the General Accountability Office, the Department of Defense, the General Services Administration, and before 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, 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.

• Defense of a leading software provider in a referral from the GSA Office of Inspector General to the Department of Justice for allegations relating to providing unqualified personnel and underreporting contract sales.
• Defense of a leading services contractor in a referral from the Library of Congress Inspector General to the Department of Justice for allegations relating to providing unqualified personnel.
• Defense of leading technology company in a qui tam action relating to non-compliance with GSA contract requirements.
• Conducted numerous investigations relating to potential non-compliance with GSA contract requirements including commercial sales practice disclosures, Price Reductions Clause compliance, and potential overcharging
• Represented numerous companies in mandatory disclosures at DoD, GSA and other agencies
• Represented numerous companies in audits, investigations and qui tam matters relating to alleged non-compliance with foreign sourcing requirements including the Buy American Act and Trade Agreements Act
• Represented numerous companies in pre-award and post-award GSA Office of Inspector General audits
• Represented numerous companies in presentations to Suspension and Debarment Officials for the Army, Air Force, 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