Last month, the Federal Acquisition Regulatory Council proposed new cybersecurity and incident reporting regulations for federal contractors on behalf of the Department of Defense (DoD), the General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA). The proposed
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Cyber Incident Reporting May Be “Material” for Federal Contractors
Last month, the Federal Acquisition Regulatory Council proposed new cybersecurity and incident reporting regulations for federal contractors on behalf of the Department of Defense (DoD), the General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA). The proposed
New Guidance Clarifies Facility Clearance Eligibility Determination Requirements for Joint Ventures
On October 5, the Information Security Oversight Office (ISOO) issued a joint notice (Joint Notice) with the Small Business Association (SBA) and in coordination with the Department of Defense (DOD) clarifying that the Cognizant Security Agency (CSA) is responsible for
GAO’s 2023 Bid Protest Report: More Than Meets the Eye
On October 26, the Government Accountability Office (GAO) sent its annual bid protest report to Congress, which reflected a dramatic increase in protests filed following four straight years of decline.
FCPA Update: DOJ Opinion Procedure Releases Underscore That Payments to Officials Are Sometimes Permitted
Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain situations. Given how rarely DOJ issues such
Examining the 3M Sanctions Settlement
In an article for Law360, I examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran.
International Trade Enforcement Roundup – October 2023 Update
GAO Assesses Health of the Defense Industrial Base
The health of the Defense Industrial Base (DIB) has been brought to the fore as the United States responds to wars in Ukraine and Israel. Unfortunately, according to the National Defense Industrial Association’s “Vital Signs” report, the U.S. DIB
The Corporate Transparency Act: A Primer for “Small” Businesses
The Corporate Transparency Act (CTA), which aims to curb illicit financial activities like money laundering and other fraudulent activities, will go into effect on January 1, 2024. Consequentially, many types of businesses, known as “reporting companies,” will be required to
CSO Requirements for Government Contractors
We recently authored an article for Reuters examining Commercial Solutions Openings, a contracting mechanism through the Department of Defense (DoD), which seeks innovative commercial technologies or services.