On December 3, 2025, the Special Inspector General for Afghanistan Reconstruction (SIGAR) issued its Final Report: Seventeen Years of Reconstruction Oversight. SIGAR identified “1,327 instances of waste, fraud, and abuse; at least $26 billion in wasted funds; and more than $4.6 billion in potential savings to the U.S. taxpayer.”

According to its own report, “SIGAR’s Audits and Inspections Directorate issued nearly 800 performance audit, evaluations, financial audits, alert letters, inspection reports, and other report types” resulting in “nearly 1,500 recommendations to recover funds, improve agency oversight, and increase program effectiveness” and “171 criminal convictions, 141 contractor suspensions, and 582 contractor debarments” with corresponding criminal fines, restitutions, forfeitures, and civil settlements. These findings were premised on the work of numerous “auditors and investigators to Afghanistan, who worked under harsh and dangerous conditions.”

As its overextended mandate concludes on January 31, 2026, SIGAR’s work is an important reminder of the immense resources federal agency Office of Inspector Generals (OIGs) and congressional committees can bring to bear. These entities are willing to investigate — and in some cases “second guess” — the work of federal contractors doing the bidding of the U.S. Government even in the most dangerous and challenging environments. As outlined in the SIGAR report, the risks of these investigations include not only potential direct civil, criminal, and financial consequences but also a federal contractor’s reputation and eligibility for future awards.

Key Takeaways in Preparing for an Increased Oversight Environment:

  • Understand the Independent and Coordinated Oversight Structure: Offices of Inspector General (OIGs) operate with independent budgets and staff, reporting directly to Congress, which drives broad investigations. At the same time, OIGs collaborate through the congressionally funded Council of the Inspectors General on Integrity and Efficiency (CIGIE) to address waste, fraud, and abuse.
  • Appreciate Broad Scope of OIG and Congressional Oversight: OIGs are empowered to investigate and arbitrate alleged fraud, waste, and abuse arising not only from intentional conduct but also conduct stemming from what is characterized as poor management or lack of oversight. That broad discretion inevitably creates a risk that a federal contractor’s good faith exercise of business judgment or discretion will be subject to scrutiny.
  • Embedded Metrics and Evaluation: SIGAR’s oversight relies heavily on data analytics performed by government agencies. Analysis of non-relational data from massed records is an increasing trend across OIG investigations. Management should adopt robust documentation practices and maintain auditable records to align with federal requirements in anticipation of analytic review. Contractors should also proactively train staff to incorporate metrics and evaluation requirements in proposals to demonstrate accountability.
  • Mitigate Risks Under the False Claims Act (FCA): OIGs may leverage the FCA and Federal Acquisition Regulation (FAR) mandatory disclosures provisions to impose liability for matters that may be unclear or disputed. Because federal contractors are subject to a myriad of contractual and regulatory compliance obligations, companies should regularly assess the accuracy of their System for Award Management (SAM) certifications and representations.
  • Establish a Formal Compliance Program: In addition to routine compliance requirements applicable in the Continental United States (CONUS), contractors operating in combat zones or other contingency environments are subject to heightened standards under the Defense FAR Supplement (DFARS) and International Humanitarian Law (IHL). Contractor compliance programs should be adequately resourced, supported by leadership, and meet or exceed federal standards. Contractors should stay up to date with new requirements and adjust their programs accordingly.

Defense, infrastructure, and humanitarian sectors face heightened risks in this environment. Proactive risk mitigation through implementation and execution of an effective compliance program and consultation with counsel on identified risks is far more effective than a purely reactive response to an OIG or Congressional investigation that is already in process.

Navigating the complex post-SIGAR oversight environment requires specialized legal counsel. Fluet’s national security focused Litigation + Investigations and Government Contracts teams can assist with OIG or other Government Investigations, as well as Congressional Investigations at all stages.