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 ConsistencySBIR/STTR Reauthorization Brings New Opportunities and New Diligence Expectations
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 ExpectationsFAR Council Moves Quickly on DEI Executive Order, Which Has Already Been Challenged in District Court
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 CourtD.C. District Court Dismisses Challenge to a “Buy America” Waiver for Brightline West High-Speed Rail Project
A federal district court in Washington, D.C. recently dismissed a lawsuit brought by Alstom seeking to overturn a Federal Railroad Administration (FRA) waiver that allows Siemens to supply certain foreign-made components for the Brightline West high-speed rail project between Las Vegas and Southern California.
Continue Reading D.C. District Court Dismisses Challenge to a “Buy America” Waiver for Brightline West High-Speed Rail ProjectUPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China
On October 30, U.S. Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will delay the implementation of the recently announced BIS Affiliates Rule for one year.
Continue Reading UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-ChinaBIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities
Please note that the content below was posted on October 2, 2025. We have since provided updated guidance on the topics discussed in this post here.
On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities and referred to by BIS as the “Affiliates Rule,” the rule is designed to close a longstanding loophole by extending restrictions to foreign affiliates of parties already subject to export restrictions, including those parties designated on the Entity List and the Military End-User (MEU) List.
Continue Reading BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed EntitiesLegal/Legislative Update at the GWSCPA 2025 Government Contracting Conference
On September 25, join me in Vienna, Virginia at the Greater Washington Society of CPAs (GWSCPA) 2025 Government Contracting Conference where I will lead a session on the latest Legislative and Legal Updates.
Continue Reading Legal/Legislative Update at the GWSCPA 2025 Government Contracting ConferenceDoD Finalizes CMMC Rule: What Defense Contractors Need to Know
The Department of Defense (DoD) has issued its long-awaited final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program into the Defense Federal Acquisition Regulation Supplement (DFARS). The rule establishes a three-year phased rollout that will ultimately apply to nearly every contractor and subcontractor handling federal contract information (FCI) and controlled unclassified information (CUI) (the new requirements do not apply to awards that do not involve the handling or transmission of FCI or CUI).
Continue Reading DoD Finalizes CMMC Rule: What Defense Contractors Need to KnowPreparing 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 Guidelines