The FTC has been active in the weeks leading up to a change in administration. The Commission has ordered that companies and the individuals who run them pay refunds paid to consumers they have allegedly misled, doubled down on enforcement
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Congress Has Spoken: DoD Unilateral Definitizations are Appealable Government Claims
In a big change for defense contractors, Congress has amended 10 U.S.C. § 3372 to make clear that a Department of Defense (DoD) contracting officer’s unilateral definitization of an undefinitized contract action is directly appealable to the Armed Services Board…
NICE and Easy: Proposed Cybersecurity FAR Amendment Incorporates NICE Framework, Standardizing Cybersecurity Workforce Descriptions
On January 3, 2025, the FAR Council released a proposed rule titled Strengthening America’s Cybersecurity Workforce (the Proposed Rule). The Proposed Rule would amend the Federal Acquisition Regulation (FAR) by standardizing workforce criteria for cybersecurity and information technology support services…
CBP Proposes Rule Imposing Greater Regulation of De Minimis Imports
U.S. Customs and Border Protection (CBP) issued a notice of proposed rulemaking concerning the de minimis exemption under 19 U.S.C. § 1321 (Section 321). Currently, the de minimis exemption allows goods with an aggregate value under $800 to enter the…
State Antitrust Enforcement: A Continued Focus on Competition During the New Administration
Key takeaway #1 Expect State Attorney General antitrust enforcement to increase in the coming four years.
Key takeaway #2 Both Democratic and Republican AGs will be active, separately and on a bipartisan basis.
Key takeaway #3 AGs likely to focus…
AMA’s CPT Editorial Panel Approves New Codes Covering Remote Patient Monitoring Services
On October 18, 2024, the American Medical Association’s (AMA’s) Current Procedural Terminology (CPT) Editorial Panel released a Summary of Panel Actions from its September 2024 Panel Meeting, which includes six new remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM)…
FAR Council Withdraws Proposed Mandatory Climate Disclosures for Federal Contractor Rule
Mandatory climate disclosures for US federal contractors are officially off the table—at least, for the foreseeable future. On January 10, 2025, the Department of Defense, General Services Administration, and National Aeronautics and Space Administration announced that they are withdrawing a…
New Year, Updated List: The U.S. Department of Defense Updates Its List of Chinese Military Companies with Ancillary Supply Chain and USG Contracting Impacts
On January 2, 2025, the U.S. Department of Defense (DoD) updated the 1260H List of entities identified as “Chinese military companies” (CMC) operating in the United States, as required by section 1260H of the National Defense Authorization Act (NDAA) for…
China Unveils New Framework To Stimulate Cross-Border Data Flows: Risk or Opportunity for Multinational Companies
As Foreign Investment in China Shrinks, China Unveils New Framework to Stimulate Cross-Border Data Flows: Risk or Opportunity for Multinational Companies?
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UK’s OTSI Publishes New Russia Evasion and Diversion Guidance
To kick-start 2025, the UK’s recently established Office of Trade Sanctions Implementation (“OTSI”) has published two related guidance notes for UK exporters on Russian trade sanctions evasion and diversion.
First, Countering Russian sanctions evasion – guidance for exporters seeks to…