In an era of historic Department of Justice enforcement and multi-agency regulatory crackdowns, Tier 1 Prime Contractors face catastrophic corporate exposure. Under the False Claims Act and federal mandatory disclosure rules, a Prime is routinely held liable for unmonitored non-compliance, status fraud, and labor misclassifications occurring deep within their 2nd- and 3rd-tier subcontractor networks.
Standard administrative software and basic clerical tracking fail to stop these hidden liabilities.
Justin Frey Law LLC delivers a specialized, independent "Sentinel" Compliance Program engineered specifically for high-consequence defense, aerospace, construction, and technical prime contracts. Founded and led by a former Felony Fraud Prosecutor with over six years of multi-agency investigative and financial crimes experience, we apply rigorous forensic scrutiny to your sub-tier supply chain.
We identify, isolate, and remediate compliance failures under the ironclad protection of Attorney-Client Privilege—giving your corporate legal team a secure "clean room" to address vulnerabilities before they escalate into federal audits, treble damages, or contract debarment .
To expedite supplier onboarding and direct-sole-source contracting, our verified federal credentials are active and current :
Federal Identifiers & Socio-Economic Certifications
Unique Entity ID (UEI): ZER4QFLJFYE4
CAGE Code: 1Z3C9
Primary NAICS Codes:
541110 – Offices of Lawyers (Primary)
541611 – Administrative Management & General Management Consulting
Secondary NAICS Utilized:
541199 (Legal Services) , 541211 (CPAs) , 541990 (Professional/Technical) , 561611 (Investigation/Background Checks)
Socio-Economic Status:
SBA-Certified Service-Disabled Veteran-Owned Small Business (SDVOSB) and Veteran-Owned Small Business (VOSB)
By embedding Justin Frey Law LLC into your project management framework, every dollar allocated to our risk mitigation cell counts directly toward your mandatory 5% federal SDVOSB subcontracting utilization goals. We do not just insulate your multi-million dollar portfolio from Department of Labor and Department of Justice enforcement—we actively protect your CPARS rating and secure your competitive standing for future agency awards.
We do not offer generic business advice or passive checklists. The Sentinel Compliance Program delivers precise, prosecutor-grade forensic analysis targeted at the exact regulatory pain points that trigger Department of Labor (DOL) investigations, False Claims Act (FCA) lawsuits, and contract debarment.
Our specialized capabilities are deployed across four critical execution pillars:
Davis-Bacon Act (DBA) & Service Contract Act (SCA) Wage Compliance Audits: We execute rigorous verification of multi-tier payrolls. Our cell maps individual field personnel classifications against the specific SCA and DBA Wage Determinations bound to the contract, catching misclassifications and fringe-benefit shortfalls before they leave your internal ecosystem.
FAR 52.203-13 Procurement Integrity Monitoring: We independently vet sub-tier billing data, material certifications, and labor logs to identify anomalies indicating pass-through entity fraud, false invoicing, or small business status misrepresentation.
Certified Payroll Auditing & Clean Rooms: Unlike clerical consulting firms, our compliance reviews operate under the protective shield of Attorney-Client Privilege. If an infraction is discovered within a sub-tier network, we deliver an immediate, confidential legal risk assessment to your General Counsel—allowing your leadership team to strategically structure remediation or proceed with an insulated FAR 52.203-13 Mandatory Disclosure.
Proactive "Tools-in-Hand" Labor Standards Interviews: Paperwork can be easily manipulated; physical reality cannot. We conduct unannounced, highly structured site-verification sweeps using Standard Form 1445 (SF-1445) Labor Standards Interview protocols. These are deployed dynamically or automatically triggered following a serious on-site safety accident to verify that active workers match certified payroll records in real-time.
Our legal and consulting framework is built to flex seamlessly between the distinct risk profiles of heavy physical infrastructure and highly sensitive technical environments:
Industrial & Civil Infrastructure
The Vulnerability: Sprawling construction sites with deep, fractured tiers of trades, vulnerable to apprentice-ratio exploitation, undocumented labor pools, and tools-in-hand trade misclassifications.
The Shield: Ground-level site inspections, ratio-creep tracking, and physical verification of certified payroll entries to insulate the Prime from catastrophic False Claims Act exposure.
Technical, Energy, & Defense Management
The Vulnerability: Lean, highly specialized professional service contracts heavily reliant on multi-state independent contractors, technical writers, and administrative support pools.
The Shield: Strict Service Contract Act (SCA) wage compliance, rigorous data-handling and safekeeping audits to prevent insider threat leaks, and continuous mapping of contract parameters against FISMA (Federal Information Security Modernization Act) mandates.
To maintain the absolute integrity and legal authority of our oversight, Justin Frey Law LLC operates strictly as an independent Legal and Operational Integrity Cell. We do not provide low-level, administrative back-office clerical services.
By drawing a sharp operational boundary, we ensure that your budget is allocated exclusively to high-value risk insulation, corporate defense, and the deployment of a former fraud prosecutor's forensic scrutiny.
We explicitly define our engagement parameters as follows:
What We Handle (Our Mandated Duties):
Independent Data Verification: We apply prosecutor-grade forensic analysis to audit the subcontractor payroll, labor, and compliance data compiled by your project teams before it is submitted to federal agencies.
Attorney-Client Privileged Scrutiny: We structure all internal risk assessments, sub-tier anomaly investigations, and corrective action plans under complete legal privilege.
Regulatory Compliance Defense: We act as your specialized strategic counsel to analyze evidence, assess False Claims Act exposure, and prepare defense or voluntary self-disclosure frameworks for your General Counsel.
Socio-Economic Certification Management: We generate, track, and validate the official monthly sub-reporting metrics (FAR 19.7) required to certify that our engagement directly satisfies your contract's mandatory 5% SDVOSB utilization quotas.
What We Refuse (Duties Remaining with the Prime's Clerical Staff):
NO Direct Portal Data Entry: Our team will not perform manual, weekly typing of hours, names, or dollar amounts into federal tracking databases (e.g., LCPtracker, eSRS, or WAWF). Your internal administrative clerks enter the data after we have audited and stamped the master files as compliant.
NO Primary Document Collection: We do not spend operational hours chasing individual 2nd- or 3rd-tier subcontractors for missing timesheets, utility bills, or onboarding paperwork. Your project managers accumulate the weekly data packets and deliver them to us as a unified file.
NO Payroll Processing: We are not a payroll vendor. We do not calculate weekly paychecks, process direct deposits, or manage tax withholdings for your firm or your subcontractors.
NO Routine Human Resources Tasking: We do not manage day-to-day employee grievances, onboarding, or general corporate benefits administration.
Our engagement is designed to be frictionless for your existing operations. Your administrative and accounting teams continue to handle routine, high-volume data entry and collection. We stand at the perimeter as an independent filter, catching structural anomalies and insulating your firm from severe federal liabilities before a non-compliant record ever touches a government database.
Do not wait for a Department of Labor audit, an active OSHA investigation, or a whistleblower qui tam lawsuit to expose vulnerabilities within your sub-tier networks. Securing your prime contract cash flow, maintaining your CPARS standing, and meeting your mandatory socio-economic requirements requires immediate, proactive insulation.
Justin Frey Law LLC is positioned for immediate, rapid-response deployment to projects across the Ohio defense, infrastructure, and energy corridors. While our physical, rapid-response site audits are geographically anchored to Ohio, our federal compliance, advisory, and remote oversight cells are fully scalable to support your prime portfolios wherever your projects are deployed nationwide.
For Tier 1 Primes seeking to evaluate our capabilities without disrupting active operational momentum, we offer a discrete, fixed-fee Supply Chain Integrity Diagnostic:
Targeted Selection: Your General Counsel or Compliance Director selects a single regional project or high-exposure subcontractor tier.
Forensic Vetting: Our independent integrity cell reviews up to four consecutive weeks of compiled sub-tier payrolls, trade classifications, and flow-down contract language.
Privileged Evaluation: We deliver a confidential, attorney-client privileged risk posture report directly to your executive legal team, outlining any hidden Davis-Bacon/SCA exposure or procurement integrity flags alongside immediate remediation strategies.
Immediate Goal Credit: Upon engagement, our certified credentials instantly apply toward your program's mandatory 5% SDVOSB utilization quotas.
To bypass standard vendor administrative delays and initiate a peer-to-peer consultation with a former fraud prosecutor, contact our federal compliance team securely:
Executive Director of Operations (DOO): Chelsea N. Ricker
Direct Compliance Inbound: chelsea@jfreylaw.com
Managing Member / Principal: Justin Frey, Esq.
Secure Legal Inbound: justin@jfreylaw.com
Federal Division Desk: 419-210-5340
Firm Website: www.jfreylaw.com
Procurement Onboarding Note: To immediately import our verified credentials into your corporate supplier management portals (such as Exostar, iSupplier, or internal Joint Venture databases), please reference UEI: ZER4QFLJFYE4 and CAGE Code: 1Z3C9. Our active SBA certifications are officially validated and indexed for direct federal contract and subcontract set-aside awards.