On September 11, 2026, the OCC, FDIC, Federal Reserve, and NCUA proposed to replace the 2023 Interagency Guidance on Third-Party Relationships with a shorter, principles-based document.1 Two companion releases complete the package: a final interagency statement on the supervision
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State AG News: Consumer Protection, Settlements, Federal Regulation (September 18-23, 2026)
Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from September 18-23, 2026:
Multistate
- A bipartisan coalition of 41
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U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows
State Department Issues Two New Rules Amending the ITAR
On Friday, September 18, 2026, the U.S. Department of State issued two rules amending the International Traffic in Arms Regulations (ITAR). The first, an interim final rule effective October 19, narrows U.S. Munitions List (USML) Category XX(a) controls on certain…
Federal Circuit Resolves Court Split Over IDIQ Awardee Standing
When an agency conducts a multiple-award indefinite delivery, indefinite quantity (IDIQ) competition, successful awardees often wonder whether they can protest the agency’s award to other companies at the U.S. Court of Federal Claims. For over a decade, the answer has…
FEATURE COMMENT: The Eleventh Circuit Overturns the Zafirov Decision on FCA Qui Tam Constitutionality
On September 1, 2026, the Eleventh Circuit issued its long-anticipated decision in U.S. ex rel. Zafirov v. Florida Medical Associates LLC, holding that the qui tam provisions of the False Claims Act are constitutional because relators are not officers of…
OFAC Creates Unified Sanctions Penalties Regulations
By Carlton Greene & Nate Young
Key Takeaways:
- Key Takeaway #1: The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule (the “Rule”), effective September 25, 2026, creating the “Sanctions Penalties Regulations” under 31 CFR Part 505: the agency’s first-ever single,
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The Lindsey Graham Sanctions Act: What Businesses Need to Know About the New Tariffs
President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, following bipartisan passage in both chambers. Among its most commercially significant provisions is a sweeping new tariff framework targeting Russia and countries…
SBA Extends Deadline for Comments on Historic Overhaul of Size Standards
On September 21, 2026, the Small Business Administration announced an extension of the comment period for two previously proposed rules that, as currently constructed, would significantly expand the pool of entities eligible to qualify for small business set-aside procurements. The…
In a First, District Court Dismisses FCA Cybersecurity Complaint for Lack of Materiality
In recent years, the U.S. federal government has taken significant interest in the cybersecurity compliance of its contractor base. In 2025 alone, the U.S. Department of Justice’s (DOJ) Civil Cyber-Fraud Initiative recovered more than $50 million across nine False Claims…