On June 29, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) launched an online Reconsideration Portal for requests to remove persons or property from OFAC sanctions lists, including the Specially Designated Nationals and Blocked Persons (SDN) List. OFAC states that the portal streamlines delisting petitions by collecting key information upfront rather than through repeated questionnaires.…

Continue Reading OFAC Launches Reconsideration Portal to Streamline Delisting Petitions

On June 17, the U.S. Department of Justice (DOJ) National Security Division (NSD) announced its first declination under the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), declining to prosecute Robert Bosch GmbH (Bosch) for potential criminal violations of the Export Control Reform Act (ECRA).

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Continue Reading DOJ Issues First Corporate Enforcement Policy Declination: Lessons from Bosch’s FDPR Export Control Resolution

As procurement fraud enforcement continues to be a priority for the Department of Justice and other federal agencies, we take a look back at significant 2025 enforcement developments affecting government contractors, grant recipients and participants in federal programs in our 2025 Procurement Fraud Review.

Continue Reading Procurement Fraud Enforcement Trends Continue Into 2026

On April 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Press Release describing a Notice of Proposed Rulemaking that would significantly reshape anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements across a wide range of financial institutions. Comments are due by June 9, 2026. 

Continue Reading FinCEN Proposed Rulemaking: Significant Revisions Centered on Risk, Effectiveness, and Supervisory Consistency

On April 15, the Federal Circuit issued a decision clarifying the burden a protestor must meet when challenging an agency’s override of the Competition in Contracting Act’s (CICA) automatic stay of performance. In Life Science Logistics, LLC v. United States, the court held that when challenging an override of CICA’s automatic stay of performance after a protest is filed at the GAO, a protestor need not demonstrate entitlement to an injunction under the standard four-factor equitable relief test. Instead, the protestor only needs to show that the agency’s override decision was arbitrary and capricious.

Continue Reading Clarified Standard for Challenging CICA Stay Overrides

After a brief lapse, Congress has reauthorized the Small Business Innovation Research and Small Business Technology Transfer programs through Fiscal Year 2031. President Trump signed the Small Business Innovation and Economic Security Act, S. 3971, into law on April 13, 2026. The legislation restores certainty to two of the federal government’s most important funding programs for small business research and development, but it is not a clean extension. The reauthorization makes several meaningful changes to the way agencies will evaluate applicants, manage Phase II and Phase III awards, and screen foreign investment risk.

Continue Reading SBIR/STTR Reauthorization Brings New Opportunities and New Diligence Expectations

On April 30, President Trump issued an Executive Order (Order) directing federal agencies to make fixed-price contracting the default and preferred procurement method across the federal government. The Order reflects the administration’s view that fixed-price contracts better promote cost predictability, contractor accountability, and performance-based outcomes than cost-reimbursement and other non-fixed-price contract types.

Continue Reading President Trump Issues Executive Order Directing Agencies to Default to Fixed-Price Contracting

On April 17, the Federal Acquisition Regulatory (FAR) Council issued guidance implementing Executive Order (EO or Order) 14398, Addressing DEI Discrimination by Federal Contractors, less than 30 days after the Order was signed and well ahead of the 60-day deadline the Order gave the Council to act. Because the Order required agencies to begin implementation within 30 days, the FAR Council likely took quick action to ensure a uniform government-wide approach to implementation of this requirement.

Continue Reading FAR Council Moves Quickly on DEI Executive Order, Which Has Already Been Challenged in District Court

Recent “Made in USA” enforcement actions show that U.S.-origin claims continue to be an active enforcement priority for the Federal Trade Commission (FTC). On April 14, the FTC announced three enforcement actions and the closure of two investigations involving companies alleged to have overstated the domestic origin of their products. The announcement followed a March 13 Executive Order (the “EO”) calling for heightened scrutiny of purportedly false “Made in America” representations.

Continue Reading FTC Signals Renewed “Made in USA” Enforcement Focus Following Trump Executive Order

We co-authored an article for Corporate Compliance Insights discussing a recent case in which the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a penalty against Applied Materials (AMAT) for $253 million, the second-largest civil penalty in BIS history.

Continue Reading Export Compliance in Line with Recent BIS Civil Penalty

From the Bass, Berry & Sims Blog Network
From the Bass, Berry & Sims Blog Network

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