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DOJ’s Aggressive Efforts to Investigate a Federal Government Contractor

On February 18, 2025, Denise Cheung, leader of the criminal division at the U.S. Attorney’s Office for the District of Columbia, abruptly resigned. Prior to her resignation, Cheung had been at the Department of Justice (DOJ)...more

Responding to Recent Guidance on OMB’s Temporary Pause of Federal Financial Assistance Programs

On January 27, 2025, the Office of Management and Budget (OMB) issued an internal memo (Memo M-25-13) directing all federal agencies to temporarily pause all activities related to obligation or disbursement of all federal...more

President Trump Revokes Executive Order 11246

On January 21, 2025, President Donald Trump issued a broad executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” Aimed at “[t]erminating Illegal Discrimination in the Federal...more

Fourth Quarter 2024 Government Contracts Policy and Regulatory Review

The fourth quarter of 2024 presented government contractors with significant changes, including annual spending bills, new rulemakings, agency announcements and a new federal administration following the election. We review...more

Third Quarter 2024 Government Contracts Policy and Regulatory Review

Federal agencies proposed or finalized several important rulemakings during the third quarter of 2024, raising new opportunities and considerations for government contractors. Below, we highlight some of these changes and...more

Department of Defense Establishes New Cybersecurity Maturity Model Certification (CMMC) Program

Following a multi-year rollout process, the U.S. Department of Defense published a final rule on October 15, 2024, establishing its Cybersecurity Maturity Model Certification Program to protect sensitive unclassified...more

Third Quarter 2023 Government Contracts Policy and Regulatory Review

The third quarter had government contractors staring down the possibility of a government shutdown while also contending with some significant regulatory developments. We review some of those developments below....more

OMB Issues Final Guidance on BABA Domestic Sourcing Requirements

On August 14, 2023, the Office of Management and Budget (OMB) released final guidance on implementing the statutory requirements of the Build America, Buy America Act (BABA) provisions of the Infrastructure Investment and...more

DOL Issues Final Rule Updating Davis-Bacon and Related Acts

For the first time in almost 40 years, the Department of Labor (DOL) announced the issuance of regulations designed to update and modernize the Davis-Bacon and Related Acts (DBRA), which require the payment of locally...more

Second Quarter 2023 Government Contracts Policy and Regulatory Review

From increased cybersecurity requirements to updated Inflation Reduction Act guidance, to a long-awaited Supreme Court decision on the False Claims Act, federal contractors had a lot to think about during the second quarter...more

Next Stage Considerations About the Supreme Court’s Affirmative Action Decision: How to Put the Warning Letter from the State...

As higher education institutions, state and local governments, private employers and federal contractors grapple with understanding the impacts of the U.S. Supreme Court’s decision in Students for Fair Admissions v. President...more

U.S. Supreme Court Invalidates Race-Conscious Admissions: Key Considerations for Postsecondary Institutions, Employers and Others

On June 29, 2023, the U.S. Supreme Court decided Students for Fair Admissions, Inc. v. President and Fellows of Harvard College, No. 20-1199, and Students for Fair Admissions, Inc. v. University of North Carolina et al., No....more

FAR Council’s Interim Rule Bans Use of TikTok in Government Contracting

On June 2, 2023, the FAR Council issued an interim final rule banning the use of a ByteDance Covered Application — better known as TikTok — in government contracting. The interim final rule implements OMB Memorandum M-23-13...more

First Quarter 2023 Government Contracts Policy and Regulatory Review

The first few months of 2023 has brought not only regulatory changes to the government contractor landscape, but also the possibility for new business opportunities in semiconductors, green procurement and infrastructure...more

EPA Announces $100 Million for Environmental Justice Projects

Federal sustainability is a priority for the Biden administration. The administration has, for example, provided unprecedented levels of funding for sustainable infrastructure projects through the Inflation Reduction Act...more

Looking Back on 2022 in Government Contracts

Government contractors witnessed significant developments ranging from infrastructure, sustainability, supply chain, and cyber security requirements to increased compliance obligations and enforcement actions in 2022. Here we...more

FAR Council Issues Proposed Climate Disclosure Rule for Government Contractors

Executive Order 14057 — “Catalyzing Clean Energy Industries and Jobs through Federal Sustainability” — made it clear that the Biden administration plans to use federal procurement policy to further its sustainability goals....more

OFCCP Extends Deadline for Individualized Objections From Federal Contractors to Production of Their 2016-2020 EEO-1 Data in...

As covered in a previous alert, on August 19, 2022, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) notified its federal contractor base that it received a request under the Freedom of...more

9/16/2022  /  EEO-1 , Federal Contractors , FOIA , OFCCP , Pay Data

Eleventh Circuit Concludes That President Biden Likely Exceeded Authority by Issuing Federal Contractor Vaccine Mandate

On August 26, 2022, the Eleventh Circuit held that President Biden likely exceeded his authority by issuing the federal contractor vaccine mandate and affirmed the district court’s injunction prohibiting the federal...more

OFCCP Revises Recent Directive on Compensation Analysis

On August 18, 2022, the U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) revised Directive 2022-01 (DIR 2022-01) to clarify its earlier guidance addressing federal government...more

OFCCP Issues Important Update About Contractor Portal Certification Process

On July 28, 2022, the Office of Federal Contract Compliance Programs (OFCCP) issued important clarifications about the certification process through its Federal Contractor Portal (Portal). As previously reported, the Portal...more

Proposed Legislation Bans U.S. Government Contractors Doing Business in Russia

All eyes have been on Ukraine since Russia launched its military invasion two months ago. The U.S. government has imposed numerous sanctions on Russia in response to the invasion and promises to continue its economic...more

New OFCCP Directive Rolls Back Previous Administration’s Contractor-Friendly CERT Principles

On March 31, 2022, the Office of Federal Contract Compliance Programs (OFCCP) issued its second directive of the Biden administration, Directive 2022-02, titled “Effective Compliance Evaluations and Enforcement.” The policies...more

Equal Pay Day Heralds New Executive Order and OFCCP Directive

On Equal Pay Day (March 15, 2022), President Biden issued an executive order aimed at advancing the effectiveness in federal contracting by promoting pay equity and transparency in tandem with the U.S. Department of Labor’s...more

Federal Court Suspends Federal Contractor Vaccine Mandate Nationwide

On December 7, 2021, the U.S. District Court for the Southern District of Georgia issued a preliminary injunction temporarily in Georgia v. Biden, halting the enforcement of Executive Order 14042 (EO 14042) nationwide. In...more

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