Lynne Halbrooks

Lynne Halbrooks’ practice focuses on helping government contractors manage compliance and enforcement risks and solve business problems.  This includes advising companies on all aspects of government compliance and representing them in internal and government investigations and audits, including whistleblower reprisal investigations, and suspension and debarment proceedings.  She has advised companies and individuals on matters involving the False Claims Act, conflicts of interest, counterfeit parts, labor charging disputes, bribery and kickbacks, the Foreign Corrupt Practices Act, responses to subpoenas, and mandatory disclosures. She also engages with colleges and universities on compliance and risk management issues.

Lynne’s extensive and unique background in the federal government and industry enables her to provide practical advice to clients facing government inquiries or enforcement actions.  She has advised senior leaders and successfully resolved complex, high-profile issues throughout her career.

Prior to joining Nichols Liu, Lynne worked as the Chief Compliance Officer and Deputy General Counsel at Acuity International; was a partner at Holland & Knight LLP; and served in leadership roles at the DoD Office of Inspector General, the Special IG for Iraq Reconstruction, the U.S. Senate Sergeant at Arms, and the Department of Justice’s Executive Office for U.S. Attorneys.

Education

• Marquette University Law School, J.D. 1988
• University of Minnesota, Duluth, B.A. 1985

Bar and Court Admissions

• District of Columbia Bar
• Minnesota State Bar
• Wisconsin State Bar

• Internal Investigations
• Contract and Grant Compliance
• Ethics and Business Conduct
• Office of Inspector General Audits and Inquiries
• Response to Federal Subpoenas
• Suspensions and Debarments
• False Claims Act litigation

• Obtained the lifting of an exclusion for an individual proposed for Debarment by the Defense Health Agency. 
• Conducted an assessment of a major private University’s compliance program and provided recommendations for improvements. 
• Successfully represented a retired Army General in a DoD Inspector General investigation by the Defense Criminal Investigative Service after accusations were made he engaged in a conflict of interest.  The government declined to pursue the matter. 
• Represented a government contractor in the investigation and resolution of a False Claims Act lawsuit filed by a former employee and the subsequent notice to show case issued by the HHS Suspension and Debarment official. 
• Conducted an assessment of a small government contractor’s Ethics and Compliance program and recommended a structure and program elements suitable for the company’s risk portfolio. 
• Conducted an internal investigation for a manufacturing company and responded to a Defense Criminal Investigative Service subpoena related to a Defense Logistics Agency. procurement. 
• Conducted an internal investigation into labor mischarging for a major Defense contractor. 
• Successfully represented a senior Air Force official being investigated by the Air Force Office of Special Investigations for conflicts of interest.  The government declined to pursue the matter. 
• Prepared and represented corporate officials interviewed by Army Criminal Investigative Service agents about counterfeit parts found in the company’s products. 
• Conducted an internal investigation for a major Defense Contractor on potential violations of the Defense Production Act.  
• Represented a government contractor in its response to a subpoena from the National Geospatial Agency.
• Represented a physician employed by a government contractor who was interviewed in connection with a patient death. 
• Conducted an internal investigation for a Defense contractor after allegations were made about staff receiving kickbacks from vendors in Afghanistan. 
• Represented a former employee of a municipality under investigation by the Department of Justice for violations of the False Claims Act.

• “Chapter Two, The Enforcement Community,” False Claims and Government Contracts: The Intersection of Federal Government Contracts, Administrative Law, and Civil Fraud, the American Bar Association 2017, 2nd ed. 2023.
• Corporate Compliance Answer Book, Corporate Compliance Monitors; The False Claims Act Chapters, Practising Law Institute, 2019 Edition (2017, 2018).
• When To Accept ADR For Defense Contractor Reprisal Cases, Law360, April 19, 2018.
• Fraud Indicators Provide Valuable Lessons for Contractors, Law360, August 18, 2015.
• “Managing Compliance Risks in Federal Grants and Contracts,” 2023 University Risk Management Management and Insurance Association Annual Conference.

• Current Legal Developments Impacting the Industry, Women Leaders in Defense & Aerospace Law & Compliance, ACI, February 26, 2020.
• What to Do When the Inspector General Knocks, D.C. Bar, March 20, 2018.
• GAO and OIG Audits and Investigations: Making the Government Turn Square Corners, Society of Corporate Compliance and Ethics Webinar, August 29, 2017.
• Practical Considerations for Managing False Claims Act Liability and Internal Investigations, American Bar Association: Section of Public Contract law Annual Meeting, August 10-12, 2017.
• What Can Now Trigger a DCAA Fraud Referral and False Claims Act Litigation: How DCAA is Investigating and Evaluating Contractors, ACI’s 8th Advanced Forum on DCAA & DCMA Cost, Pricing, Compliance and Audits, June 14, 2017.
• The DoD Office of Inspector General – An Insider’s Perspective, Defense Industry Initiative Webinar, October 22, 2015.
• Trending Compliance Issues, National Contract Managers Association Program, October 21, 2015, Surviving the Knock on the Door, The Professional Services Council Annual Conference, October 5, 2015.
• National 8(a) Association 2015 Summer Conference, Inspector General and Oversight Trends, June 16-17, 2015.