As we noted in this blog post in February, the 2025 National Defense Authorization Act (NDAA) was enacted in December 2024 included a provision at Section 885 raising the protest threshold for Department of Defense (DoD), Coast Guard, and NASA task orders from $25 million to $35 million.
Continue Reading GAO Proposes Higher Pleading Standard for Bid Protests, Questions Remain for Loser-Pays ModelU.S. Government Ends Sanctions on Syria
On June 30, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has also lifted nearly all sanctions on Syria.
Continue Reading U.S. Government Ends Sanctions on SyriaCFIUS and President Trump Force Unwinding of 2020 Acquisition of Jupiter Systems, LLC
On July 11, the Trump administration issued an order blocking and requiring the unwinding of a 2020 acquisition by which Jupiter Systems, LLC (Jupiter), a U.S.-based audiovisual equipment supplier, was acquired by Suirui International Co., Limited (Suirui), a Chinese-based cloud communication service carrier. The administration cited national security concerns due to “the potential compromise of Jupiter’s products used in military and critical infrastructure environments.”
Continue Reading CFIUS and President Trump Force Unwinding of 2020 Acquisition of Jupiter Systems, LLCSanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure
In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. OFAC is the primary U.S. government agency that administers and enforces U.S. sanctions.
Continue Reading Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition DisclosureChanges Related to Small Business Federal Contracting Goals
I recently authored an article for Federal News Network offering insight on adjustments made by the Trump administration related to small business federal contracting goals moving forward.
Continue Reading Changes Related to Small Business Federal Contracting GoalsCompliance with Limitation on Subcontractor is Ostensible Subcontractor Safe Harbor
On June 2, the Small Business Administration’s (SBA) Office of Hearing and Appeals (OHA) denied a size appeal filed by Veteran Elevator Solutions, LLC (VES) challenging the size of Bass, Berry & Sims’ client GD Resources, LLC (GD Resources). This decision demonstrates the application of the 2023 “safe-harbor” addition to the ostensible subcontractor rule as previously discussed in an earlier blog post.
Continue Reading Compliance with Limitation on Subcontractor is Ostensible Subcontractor Safe HarborMentor Protégé Joint Venture Size Determination – A Responsible Manager Must Retain Exclusive Responsibility
The Small Business Administration’s (SBA) Mentor-Protégé Program allows a large company to joint venture with a smaller firm without the two entities being treated as one for size purposes – so long as a joint venture agreement gives the protégé managerial control. Size Appeal of Acacia7 JV shows how drafting loose managerial terms can lead to an unfavorable outcome.
Continue Reading Mentor Protégé Joint Venture Size Determination – A Responsible Manager Must Retain Exclusive ResponsibilityPreparing for the Unexpected: Legal and Strategic Considerations in Federal Contract and Grant Terminations
Federal contractors and grant recipients are no strangers to changing requirements and evolving priorities. But in recent months, we’ve seen a noticeable increase in stop work orders, early terminations, and administrative actions that directly impact performance, cash flow, and compliance obligations.
These situations are rarely straightforward. Agencies may issue stop work orders based on shifting funding or political directives. Terminations may stem from compliance findings or performance concerns, even when the root causes are unclear or disputed. Contractors and recipients must be ready to respond quickly with a sound understanding of the legal framework and a plan for recovery.
To help navigate this complex landscape, we hosted a webinar with Donna Dominguez of Aprio.
Continue Reading Preparing for the Unexpected: Legal and Strategic Considerations in Federal Contract and Grant TerminationsIs the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines
On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the U.S. Department of Justice (DOJ) laying out the evaluation criteria and a non-exhaustive list of factors the Criminal Division should use to decide whether to pursue a Foreign Corrupt Practices Act (FCPA) case. The FCPA is the primary law by which the U.S. government seeks to prosecute and penalize bribery of non-U.S. government officials.
Continue Reading Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces GuidelinesHow International Companies Should Navigate Supply Chain Scrutiny
I recently co-authored an article with Natasha Buchler, head of ESG at Aperio Intelligence, to provide advice for companies on how to protect themselves from supply chain disruption and compliance challenges.
Continue Reading How International Companies Should Navigate Supply Chain Scrutiny