On August 7, the Federal Acquisition Regulatory (FAR) Council issued a final rule, published in the Federal Register, clarifying that an offeror must be registered in the federal System for Award Management (SAM) when submitting an offer and when the contract is awarded.
Continue Reading FAR Final Rule Clarifies SAM RegistrationHuge Export Penalty for U.S. Technology Company
On July 28, various arms of the U.S. government announced concurrent export enforcement resolutions involving Cadence Design Systems, Inc. (Cadence), a California-based software and technology firm. Cadence will pay over $140 million in combined net criminal and civil penalties and forfeiture.
Continue Reading Huge Export Penalty for U.S. Technology CompanySmall Business Alert – Possible End for the Rule of Two?
The federal government’s commitment to supporting small businesses through procurement remains strong, but the shape and scale of that support may soon look very different. In accordance with recent executive orders, sweeping changes to acquisition policies are already underway and the future of key non-statutory provisions favoring small businesses is uncertain. While there has been no clear indication that the Federal Acquisition Regulation (FAR) Council intends to eliminate one of the most important of those provisions, known as “the Rule of Two,” its non‑statutory status means such a move is within the realm of possibility and is likely the reason that, as noted below, legislation codifying the Rule of Two was introduced earlier this year. This uncertainty underscores how dynamic the government contracting landscape has become and raises important questions about how reforms could impact small businesses that rely on federal contracts.
Continue Reading Small Business Alert – Possible End for the Rule of Two?Guidance on Compliance Challenges in Oil and Gas Industry
I recently authored an article for World Pipelines providing guidance on compliance challenges in the oil and gas industry.
Continue Reading Guidance on Compliance Challenges in Oil and Gas IndustryGAO Proposes Higher Pleading Standard for Bid Protests, Questions Remain for Loser-Pays Model
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 8, 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 Harbor