Sanborn Map Company: Alleged Unapproved Subcontracting on Military Mapping Work

In the Sanborn Map settlement, Sanborn Map Company agreed to pay $2.1 million to resolve allegations of unapproved subcontracting and unrelated charges on Army Corps of Engineers mapping contracts. For someone assigning map work or reviewing project charges, the questions reach directly into the job: who was allowed to do the work, who actually did it and which contract got the bill.

Sanborn, headquartered in Colorado Springs, Colorado, provides photogrammetric mapping and geographic information system services. The Justice Department announced the settlement on February 7, 2014, following a former employee’s False Claims Act case over the company’s government work.

What the Government Alleged About the Mapping Work

The government alleged that Sanborn used unapproved subcontractors and charged unrelated work to Army Corps mapping contracts. From 2005 through 2011, those projects included maps for U.S. convoy routes in Iraq, Marine Corps bases in the United States and other military and civilian projects.

The Justice Department alleged that Sanborn used unapproved foreign subcontractors on three projects to save money, violating contractual obligations and causing delays. We see an upside-down bargain in that allegation: savings for the contractor, delays for the military customer waiting for its maps.

The domestic subcontracting allegation concerned an express promise to keep the work inside the company. The government alleged that Sanborn used unapproved domestic subcontractors when it was required to complete all map work in-house. It also alleged that the company billed the government contracts for unrelated work.

Who Performed the Work Behind the Contract?

The prime contractor contracts directly with the government. A subcontractor supplies goods or services to that contractor or another subcontractor, including through a purchase order. An outside firm doing the mapping can therefore be part of the work behind a government contract that names only the prime.

The same question about who performs the work arises in defense research contract fraud, where a proposal can promise work by one company that another actually performs. Sanborn’s contracts concerned mapping, and the government’s allegations turned on subcontractor approval and an in-house performance requirement. Someone assigning the mapping work may know about a handoff that the company’s name on the contract does not explain.

Subcontractor visibility also matters in the wider military-services business. In its 2022 report, Hidden Costs: US Private Military and Security Companies and the Risks of Corruption and Conflict, Transparency International Defence and Security recommended reporting subcontractor identities, ownership and the itemized value of their services, including firms beyond the first and second tier. Its recommendation tied that information to the request for payment:

The report’s recommendation puts the performer beside the invoice, which is also the useful connection for an insider who knows that work promised in-house went to an outside firm. We examine that connection against the particular contract’s requirements and approvals.

Unrelated Work Can Reach a Government Bill

The allegation that Sanborn charged unrelated work raises a separate question about the identity of the job being billed. A work record can show that somebody did a task while the project assignment explains whether that task belonged to the government contract. Time sheets, job codes and contract requirements answer different parts of that question.

The whistleblower complaint against Huntington Ingalls Industries alleged that supervisors directed crews’ hours to hull numbers unrelated to the ships the crews actually worked on. Someone assigning a mapping project may likewise know which job a charge actually served. The internal project number can carry the disagreement all the way to the government’s bill.

A Former Employee Brought the Sanborn Case

The Sanborn allegations arose from a former employee’s qui tam case filed in federal court in St. Louis, Missouri. That employee brought the case under the False Claims Act, which allows private individuals to sue on the government’s behalf and share in a recovery.

The former employee’s role shows why knowledge inside the contractor matters in a defense contractor whistleblower claim. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

What Evidence Is Needed to Prove Fraud?

We work with you to connect the contract’s promised performer, the actual work and the government’s bill. The in-house requirement and subcontractor approvals explain who was authorized to carry out the mapping. Work assignments and subcontractor records can identify who actually performed it, while project charges connect that work to the bill.

Different people may understand different parts of that account. A project manager may know why a job was sent outside, a person doing the mapping may know whose work came back, and an accounting employee may know which government contract received the expense. We work through those connections with you, including the relationship between an outsourcing decision, a project delay and the company’s request for payment.

Sanborn’s alleged unrelated charges also make the purpose of the expense important. We look at the work a cost supported alongside the contract charged for it, so your knowledge of the project can explain what the accounting entry alone leaves unanswered. The useful starting point is the discrepancy you understand from doing the job.

You Know Who Did the Mapping

If you saw mapping work sent outside despite an in-house requirement, or unrelated costs charged to a military project, talk with our whistleblower experts about the work and the bill. We build your strongest case around the performance promises and charges you understand, bring in defense contractor fraud whistleblower lawyers with the relevant contracting experience, and stay beside you as the case develops.