We are looking forward to presenting on Foreign Ownership, Control or Influence, or FOCI, during a webinar hosted by MD APEX on February 7. In an increasingly global economy, for those companies interested in doing classified work for the U.S. Government it is vitally important to understand what constitutes FOCI and how such concerns can be mitigated.

Continue Reading [WEBINAR] Foreign Ownership, Control, or Influence (FOCI)

You are reading the December 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.

Continue Reading International Trade Enforcement Roundup – December 2023 Update

On December 26, the Department of Defense (DoD) published its long-awaited Cybersecurity Maturity Model Certification (CMMC) Program proposed rule, which places comprehensive cybersecurity and information security requirements on DoD contractors and subcontractors.

Continue Reading Department of Defense Publishes Long-Awaited CMMC Proposed Rule

A key aspect of SBA’s All Small Mentor Protégé Program (ASMPP) is the opportunity for mentors and protégés to form joint ventures to bid together on federal contracts and qualify as a small business.

Continue Reading [WEBINAR] SBA ASMPP Joint Ventures: Best Practices for Successful Partnerships

On November 17, the Department of Defense (DoD) issued a final rule, implementing Section 874 of the National Defense Authorization Act (NDAA), clarifying that certain DoD-unique statutes and Defense Federal Acquisition Regulation Supplement (DFARS) clauses are inapplicable to DoD commercial item procurements, including acquisitions of commercial off-the-shelf items and commercial services. The changes aim to reduce barriers to entry and administrative burden for nontraditional defense contractors and streamline DoD procurement of innovative technologies from the private sector.

Continue Reading New Rule Seeks to Streamline DoD Commercial Product and Service Procurements

I recently authored an article for Law360’s Expert Analysis column outlining a joint notice issued by the Information Security Oversight Office (ISOO), which offers guidance to government contractors regarding entity eligibility determination (EED) requirements for joint ventures.

Continue Reading New Requirements for Government Contractors and Joint Ventures

On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation into violations of the Foreign Corrupt Practices Act (FCPA). In addition to the DPA, Freepoint agreed to pay over $98 million in penalties.

Continue Reading FCPA Enforcement Update: Commodities Trader Agrees to Almost $100 Million Fine