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847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments

Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026. Section 847 of the National Defense Authorization Act for FY 2020...more

Pentagon Unveils $984 Million Loan Program to Promote Critical Technologies

The Defense Department will provide loans and loan guarantees to support commercial supply chains for technologies that are critical to U.S. national security. The Defense Department Office of Strategic Capital will carry...more

Army Seeks Micro-Reactor Nuclear Power Plants to Reduce Reliance on Off-Site Electricity Providers

The Defense Innovation Unit has released a solicitation seeking Solution Briefs for full lifecycle micro-reactor power plant(s) that would start operations at an Army installation in the continental United States before the...more

Revised Uniform Grants Guidance Reduces Burdens While Encouraging Accessibility and Transparency

On April 4, 2024, the White House released a pre-publication final rule substantially updating the Office of Management and Budget (OMB) Uniform Grants Guidance, which sets the foundational requirements for agencies in making...more

Sweden’s NATO Membership Is Official! Significant Business Opportunities Now Available to Swedish Companies

Sweden’s accession to NATO provides not only increased political stability in Northern Europe, but also presents significant opportunities to Swedish companies. On March 7, 2024, after a nearly two-year delay, Sweden...more

DoD Publishes Final Rule Implementing Executive Order 14005

The rule conforms applicable DFARS clauses to the final FAR rule that was published on March 7, 2022. Contractors must comply with increasing U.S. and qualifying country content thresholds for manufactured end products—65...more

National Institute of Standards and Technology Seeks Public Comment on Draft Interagency March-In Framework

Under certain circumstances, federal agencies have statutory authority to force inventors of patented technology developed with federal funding to grant licenses allowing others to practice the invention. This authority is...more

Department of Energy Proposes to Revise its Acquisition Regulation

The DOE proposes to update and streamline its policies, procedures, provisions and clauses applicable to its contracts. The changes include revisions related to facility clearances, Agreements for Commercializing...more

ISOO Guidance on Facility Security Clearances for Joint Ventures

On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program...more

Interim Rule Establishes New Supply Chain Diligence Requirements for Contractors

A new interim rule aimed at safeguarding the federal supply chain prohibits contractors from delivering or using covered articles and sources subject to exclusion or removal orders issued under the Federal Acquisition Supply...more

OMB Finalizes “Build America, Buy America” Domestic Content Guidance

The Build America, Buy America Act generally requires that non-federal government infrastructure projects that benefit from federal government funding impose requirements for the use of domestic iron and steel and...more

Proposed Rule Increases Buy American Act Content Thresholds for DoD Contracts

The Department of Defense has proposed an amendment to the Defense Federal Acquisition Regulation Supplement to align with the Federal Acquisition Regulatory Council’s update to the Federal Acquisition Regulation in...more

DoD Announces Overhaul of FMS Process to Overcome Inefficiencies

The Department of Defense intends to overhaul the Foreign Military Sales program to alleviate long-standing bureaucratic hurdles. The overhaul is based on recommendations by a “Tiger Team” of DoD senior experts....more

IRS, Department of Treasury Release Guidance on Domestic Content Rules for Energy Projects

The Guidance sets out the requirements for using domestic steel, iron and manufactured products in order for a project to be eligible for the domestic content bonus credit amount. Projects that meet the domestic content...more

DFARS Proposed Export Controls Rule Would Require Supplying DCMA with Copy of Relevant Export Authorizations

On March 22, 2023, the Department of Defense (DoD) published a proposed rule to amend Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.225-7048. This amendment would implement an additional export control...more

4/11/2023  /  DCMA , DFARS , Exports

OMB Proposes Revisions to Guidance Supporting the Implementation of IIJA’s Build America, Buy America Act Provisions

Funding provided under the Infrastructure Investment and Jobs Act (IIJA) is conditioned on complying with domestic content requirements. The Office of Management and Budget (OMB) has proposed new regulations to implement...more

Final Rule Increases Compliance Obligations Under the Buy American Act

The FAR Council’s final rule makes changes to the Federal Acquisition Regulation that will materialize over the next decade. Contractors will have until October 25, 2022 to comply with a 60 percent domestic content...more

Biden Administration Proposes Significant Increases to Buy American Domestic Content Requirements – Takeaways for Contractors and...

On July 30, 2021, the Biden Administration published a Proposed Amendment to the Federal Acquisition Regulation (FAR) (Proposed Rule) that, among other things, would impose significantly increased U.S. content requirements...more

No Clear Answer to Address New Executive Order’s Effect on Recently Issued Buy American Regulations

President Biden issued a new Executive Order concerning Buy American regulations less than a week after the FAR Council finalized a rule that increased domestic content requirements. President Biden’s Executive Order...more

President Biden Issues Order on “Made in America Laws”

On January 25, 2021, President Biden issued Executive Order (E.O.) 14005 to implement the President’s domestic sourcing and manufacturing policy agenda by tightening federal procurement and contracting requirements and...more

India Announces New Opportunities for Defense Contractors, Investors

As part of the Indian government’s initiatives to revitalize the Indian economy, particularly defense manufacturing, it recently announced new initiatives aimed at foreign defense contractors and investment. The Indian...more

OFCCP Issues Guidance For Workplace Training Related to Race and Sex Stereotypes

The Department of Labor, Office of Federal Contract Compliance Programs (OFCCP) issued guidance concerning recently issued Executive Order 13950 (EO) which prohibits federal contractors from including certain concepts related...more

Executive Order Prohibits Workplace Training Related to Race and Sex Stereotypes

Executive Order 13950 (EO) prohibits federal contractors from including “divisive” concepts related to race and sex stereotypes in workplace trainings. The EO will require all federal contracts to include a prohibition on...more

Updated List of U.S. National Security Actions Impacting Supply Chains

Pillsbury’s International Trade team is tracking developing U.S. government measures with widespread implications for the tech, telecom and government contracting industries. The Trump administration has long focused on...more

Supply Chain Threats and Cybersecurity Compliance Issues on the Horizon

New rules and developments continue to proliferate as the U.S. government seeks to minimize supply chain threats and cybersecurity risks. For contract awards issued after August 13, 2020, prime contractors must conduct a...more

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