News & Analysis as of

Beneficial Owner Federal Contractors

Holland & Knight LLP

DCSA Releases Updated Standard Form 328, Certificate Pertaining to Foreign Interests

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The Defense Counterintelligence and Security Agency (DCSA) published a press release on May 9, 2025, announcing an updated Standard Form 328 (SF-328), Certificate Pertaining to Foreign Interest. The updated form was approved...more

Pillsbury Winthrop Shaw Pittman LLP

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

Holland & Knight LLP

DOD Proposed Rule Will Expand FOCI Requirements to Non-Classified Defense Contracts

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U.S. Department of Defense (DOD) contractors with foreign ownership, control, or influence (FOCI) soon will face new requirements. Though cleared DOD contractors have long been bound by FOCI obligations, the new rule will...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – December 2024

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Corporate Transparency Act, Part 4: Reporting Requirements Temporarily Suspended - As you may have been following, PilieroMazza previously reported on the requirements of the Corporate Transparency Act (CTA) and the...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – October 2024 #4

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Corporate Transparency Act, Part 2: Exempt Status, Physical Office, Dissolved and Tribal Entities, and Beneficial Ownership Information - The Corporate Transparency Act (CTA), which came into effect on January 1, 2024, has...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – July 2024 #2

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Small Business Administration (SBA) Notification: 7(a) Working Capital Pilot Program - On July 15, SBA published a notification of the pilot program and requested comments to provide SBA 7(a) guaranteed lines of credit up...more

Wiley Rein LLP

Small Business Contractors: Beware of Corporate Transparency Act’s Potential Pitfalls

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Starting this year, certain companies are required to submit new reports related to their ownership and control that could highlight deficiencies in their small business contracting program eligibility. On September 30, 2023,...more

PilieroMazza PLLC

Corporate Transparency Act Updates for Government Contractors and Commercial Businesses: Constitutionality, Exemptions, and...

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The Corporate Transparency Act (CTA), which came into effect on January 1, 2024, has significant implications for government contractors and commercial businesses. This client alert summarizes recent developments in the...more

PilieroMazza PLLC

The Corporate Transparency Act: Updates, Requirements, and Enforcement for Small Businesses

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The Corporate Transparency Act (CTA) has been a hot topic for small business owners since its inception. As we approach its effective date on January 1, 2024, it’s crucial to understand CTA’s implications for small...more

Nutter McClennen & Fish LLP

The Corporate Transparency Act: FinCEN to Collect Beneficial Ownership Information

The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more

Society of Corporate Compliance and Ethics...

Gary Kalman on Corruption and Compliance Programs

The playing field for anticorruption never stops changing, with new laws and new risks constantly arising. To help sort things out, and to gain his insight into other compliance challenges, we sat down with Gary Kalman,...more

Miller Canfield

New Corporate Transparency Act Will Impose Beneficial Ownership Reporting Requirements on Many Companies, Particularly Small...

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The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more

Winstead PC

A Brave New World: U.S. Implements Company UBO Reporting Regime

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Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more

Bradley Arant Boult Cummings LLP

Trust but Verify: Disclosure of Trust Ownership May Be Required for Family-Owned Government Contractors

Family-owned businesses are often owned and controlled by family trusts. Trusts are used by families for estate planning, tax planning and asset protection. Family-owned government contractors with trust ownership structures...more

Holland & Knight LLP

GAO Urges Transparency in GSA Leasing Practice for Foreign-Owned Real Estate

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On January 3, 2017, the United States Government Accountability Office (GAO) delivered a report to Congress recommending that the General Services Administration (GSA) inform tenant agencies when leasing high-security space...more

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