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Disclosure Requirements Federal Contractors

Holland & Knight LLP

"Byrd" Is the Word for Federal Grantees

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President Donald Trump on Aug. 28, 2025, signed a presidential memorandum directing U.S. Attorney General (AG) Pam Bondi to investigate whether federal grant funds are being used for lobbying and political activities in...more

Cozen O'Connor

Ninth Circuit Orders Release of Federal Contractor EEO-1 Reports: What Federal Contractors Need to Know Now

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On July 30, 2025, the Ninth Circuit ruled that the U.S. Department of Labor (DOL)’s Office of Federal Contract Compliance Programs (OFCCP) must disclose federal contractor EEO-1 reports to the Center for Investigative...more

Bradley Arant Boult Cummings LLP

The Keep Call Centers in America Act of 2025: What Financial Services Companies Need to Know

On July 29, 2025, Sens. Ruben Gallego (D-AZ) and Jim Justice (R-WV) introduced the Keep Call Centers in America Act of 2025. The act targets the offshoring of call center operations, imposes new disclosure rules for customer...more

McGlinchey Stafford

9th Circuit: Federal Contractor Workforce Reports Not Exempt Under FOIA

McGlinchey Stafford on

On July 30, the 9th Circuit Court of Appeals settled a long-standing debate between federal contractors and journalists when it ruled on Center for Investigative Reporting v. United States Department of Labor. Their decision...more

Proskauer - Government Contractor Compliance...

Ninth Circuit Orders Release of Federal Contractor EEO-1 Reports

On July 30, 2025, the U.S. Court of Appeals for the Ninth Circuit ruled that the Department of Labor (“DOL”) must disclose federal contractor EEO-1 Reports requested by the Center for Investigative Reporting (“CIR”). The...more

Jackson Lewis P.C.

Ninth Circuit Affirms Disclosure of EEO-1 Reports Under FOIA

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On July 30, 2025, the Ninth Circuit Court of Appeals upheld a district court order requiring the U.S. Department of Labor (DOL) to release EEO-1 reports previously withheld in response to Freedom of Information Act (FOIA)...more

Constangy, Brooks, Smith & Prophete, LLP

Appellate court orders disclosure of contractors’ EEO-1 Reports

The Ninth Circuit rules that FOIA does not protect data from disclosure.  As we previously reported, the Center for Investigative Reporting and its reporter Will Evans are battling the U.S. Department of Labor over its...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Ninth Circuit Orders Disclosure of Federal Contractors’ 2016–2020 Consolidated EEO-1 Data

In a ruling significant to federal contractors and government transparency advocates alike, the U.S. Court of Appeals for the Ninth Circuit has affirmed a district court order requiring the U.S. Department of Labor (DOL) to...more

Jackson Lewis P.C.

Hiring Former Government Employees: Legal Risks + Other Considerations for Contractors

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For government contractors, one consequence of the Trump Administration’s efforts to reduce the size of the federal workforce is the availability of recently departed (or actively looking to depart) government employees. This...more

Holland & Knight LLP

Podcast - Navigating the Updated SF-328 Form

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In the 22nd episode of "Are We All Clear? Facilitating Security Clearances," host Marina O'Brien is joined by Washington, D.C., International Trade attorney Andrew McAllister to help break down the Defense Counterintelligence...more

Proskauer - Government Contractor Compliance...

OFCCP Seeks Voluntary Disclosures from Federal Contractors on EO 14173 Compliance

On June 27, 2025, Office of Federal Contract Compliance Programs (“OFCCP”) Director Catherine Eschbach issued a letter announcing that OFCCP is “providing all federal contractors withthe opportunity to volunteer informationin...more

Bond Schoeneck & King PLLC

OFCCP Invites Federal Contractors to Voluntarily Disclose Efforts to Wind Down Executive Order 11246 Obligations

July 2, 2025 By: Christa Richer Cook On June 27, 2025, the Office of Federal Contract Compliance Programs (OFCCP) announced in a letter to federal contractors that they were invited to share information regarding their...more

Goodwin

Updated Standard Form 328, “Certificate Pertaining to Foreign Interests”

Goodwin on

On May 12, 2025, the Defense Counterintelligence and Security Agency (DCSA) released an updated Standard Form 328 (SF-328), “Certificate Pertaining to Foreign Interests.”...more

Constangy, Brooks, Smith & Prophete, LLP

OFCCP invites contractors to disclose efforts to wrap up EO 11246 compliance

File under “thanks, but no thanks.” In an open letter to contractors, Catherine Eschbach, Director of the Office of Federal Contract Compliance Programs, offers contractors the opportunity to explain how they have wound...more

Berkshire

OFCCP Requests Voluntary Reporting of EO 14173 Compliance

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Earlier today, OFCCP Director Catherine Eschbach sent an email letter to federal contractors offering the “opportunity to provide information about their efforts to wind down compliance with the EO 11246 regulatory scheme and...more

Jackson Lewis P.C.

OFCCP Invites Voluntary Disclosures from Federal Contractors Regarding Executive Order 14173

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In a letter dated June 27, 2025, sent to federal contractors and posted on its website, the Office of Federal Contract Compliance Programs (OFCCP) announced it is providing federal contractors the option to voluntarily submit...more

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

Bradley Arant Boult Cummings LLP

6 Tips for Government Contractors to Avoid, Neutralize, and Mitigate Organizational Conflicts of Interest

Organizational conflicts of interest (OCIs) continue to be a critical compliance risk in the federal contracting landscape. The Federal Acquisition Regulation (FAR) mandates that contracting officers “avoid, neutralize, or...more

Wiley Rein LLP

GSA Announces Expansion of “Transactional Data Reporting” Program, Reducing Compliance Obligations for GSA Schedule Contractors

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WHAT: The U.S. General Services Administration (GSA) recently announced its planned expansion of the Transactional Data Reporting (TDR) program, which will make TDR mandatory for GSA Schedule contractors whose contracts...more

Holland & Knight LLP

GSA Expands Transactional Data Reporting Requirements for MAS Contract Holders

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Multiple Award Schedule (MAS) contractors not presently participating in transactional data reporting (TDR) will now have to do so and come into compliance with the TDR rule soon after their MAS contract's Special Item...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

DLA Piper

DCSA Updates SF-328 for Cleared US Government Contractors and Academic Institutions

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The Defense Counterintelligence and Security Agency (DCSA) announced the approval of updates made to the Certificate Pertaining to Foreign Interests, or Standard Form (SF) 328, on May 7, 2025. This revised form requires more...more

Robinson+Cole Data Privacy + Security Insider

Insight Into DOGE’s Access to HHS’ Systems

Becker’s Hospital Review reports that the Department of Government Efficiency (DOGE) “has access to sensitive information in 19 HHS databases and systems,” according to a court filing obtained by Wired. HHS provided the...more

Bass, Berry & Sims PLC

Key Takeaways from DOJ’s Continued Cybersecurity Enforcement

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On March 25, the U.S. Department of Justice (DOJ) announced a $4.6 million settlement with MORSECORP, Inc. (MORSE) over its alleged failures to satisfy cybersecurity requirements for federal defense contractors....more

Akin Gump Strauss Hauer & Feld LLP

Addressing Risks from Susman Godfrey (Trump EO Tracker)

Employees of the law firm Susman Godfrey LLP (Susman) will have any active security clearances suspended. Also, all government contractors are required, to the extent permitted by law, to disclose any business they do with...more

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