News & Analysis as of

Federal Acquisition Regulations (FAR) Suspensions & Debarments

Stinson LLP

Possible Relief from New Tariffs — and Risks to Avoid

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Tariffs have been in the news almost daily. Not only have tariff rates changed repeatedly, but the deadlines around implementation are subject to change. Meanwhile, the list of new commodities that are subject to additional...more

Dickinson Wright

The Air Force “Contractor Responsibility Watch List” De Facto Debarment for Space Companies?

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The Air Force is showing increased interest in using its Contractor Responsibility Watch List (CRWL). This is for companies that, in the agency’s view, should be blocked from further space projects. ...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – March 2025 #2

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March 2025: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors - On top of the uncertainty introduced through the Trump administration’s shifting priorities and rapid-fire executive orders,...more

PilieroMazza PLLC

Guilty Until Proven Innocent: Key Takeaways from the Recent Final Rule on the FAR’s Suspension and Debarment Procedures

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In a recent Final Rule (Rule) made effective January 17, 2025, the Federal Acquisition Regulation’s (FAR) suspension and debarment procedures were revised to be more consistent with the procedures in 2 CFR part 180 applicable...more

Pillsbury Winthrop Shaw Pittman LLP

Navigating Stop-Work and Suspension Orders Under Trump 2.0

Federal contractors and grant recipients facing stop-work or suspension orders are entitled to reimbursement of costs and added performance period. In its first two weeks, the new Trump administration has introduced a flurry...more

Morrison & Foerster LLP - Government...

Pause Patrol: What to Do If the New Administration Yanks the Leash on Your Contracts or Grants

A flurry of presidential directives, agency communications, and court orders has left federal contract and grant recipients with operational disruptions and in a state of confusion. As we write, it has been difficult to...more

Hogan Lovells

FAR Council Finalizes Revisions to FAR Part 9’s Suspension and Debarment Regulations

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On January 3, 2025, the Department of Defense, General Services Administration, and National Aeronautics and Space Administration (collectively, the Federal Acquisition Regulation (FAR) Council) issued a final rule, Improving...more

Cohen Seglias Pallas Greenhall & Furman PC

Changes to the Suspension and Debarment Rules in 2025

A contractor who is proposed for debarment is effectively debarred as soon as the notice letter is received. It is like being sentenced before trial and it can take weeks, or months, for the contractor to convince the...more

Blank Rome LLP

Three Major Features of the New Final Rule on Suspension and Debarment

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Introduction - On January 3, 2025, the Federal Acquisition Regulatory Council (“FAR Council”) published a long-awaited final rule to update suspension and debarment procedures. 90 Fed. Reg. 507. The final rule takes...more

Maynard Nexsen

FAR Council Publishes Final Rule to Update Suspension and Debarment Procedures

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On January 3, 2025, the Defense Department, GSA, and NASA (together, the "FAR Council") published its final rule amending the suspension and debarment procedures under the Federal Acquisition Regulation ("FAR"). The rule,...more

Morrison & Foerster LLP - Government...

Shoot First, Ask Questions Later: Final Rule Keeps FAR’s Inconsistent Treatment of Proposed Debarments

The Federal Acquisition Regulation (FAR) Council has issued a final rule, effective January 17, 2025, to improve the consistency between the procurement and nonprocurement procedures for suspension and debarment. The changes,...more

Wiley Rein LLP

FAR Council Issues Long-Awaited Final Rule to Harmonize (Almost) Procurement and Nonprocurement Suspension and Debarment Rules

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WHAT: On January 3, 2025, the Federal Acquisition Regulation (FAR) Council published its final rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more

Clark Hill PLC

A Cautionary AI Tale for Federal Contractors

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Much has been and will be written on responsibility determinations and compliance programs in federal contracting, particularly at the intersection of cybersecurity and recent developments. Although a federal contract is not...more

Holland & Knight LLP

Small Business Subcontracting Plans: Do Lessors Need Them, and What Do They Do?

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First-time landlords to the government are often overwhelmed by the number of Federal Acquisition Regulation (FAR) and General Services Acquisition Regulation (GSAR) clauses included in government leases. The compliance...more

Blank Rome LLP

My Company Just Got a Notice of Proposed Debarment. Now What?

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Receiving a Notice of Proposed Debarment from a federal agency Suspending and Debarring Official (“SDO”) is an alarming moment for any government contractor. It means the government believes there is a basis to question...more

Seyfarth Shaw LLP

FAR Council Proposes Revisions to Suspension and Debarment Rules

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Suspension and debarment are among the most powerful administrative remedies the Government has at its disposal to address non-compliance with laws and regulations, and to protect the Government’s business interests....more

Wiley Rein LLP

FAR Council Proposes Changes to Harmonize Procurement and Nonprocurement Suspension and Debarment Rules

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WHAT: On January 9, 2024, the Federal Acquisition Regulation (FAR) Council published a proposed rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more

Venable LLP

A New Rule Runs an End Around Suspension and Debarment Regulations and Will Require Contractors to Scour Their Supply Chains for...

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In recent years, we have seen statutory and regulatory exclusions from federal contracting of various entities and their goods and services happening outside the normal suspension and debarment process, the most notable being...more

Womble Bond Dickinson

DOJ Strike Force Nabs Another Government Contractor

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On January 17, the Antitrust Division of the Department of Justice announced that it had obtained another in a recent string of guilty pleas as a result of investigations into government contracting by the Procurement...more

Bass, Berry & Sims PLC

Annual Suspension and Debarment Report Serves as a Reminder to “Turn Square Corners” When Dealing with the Government

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The Interagency Suspension and Debarment Committee (ISDC) recently released its annual report to Congress regarding suspension and debarment across the federal government in FY 2019. The report serves as a yearly reminder...more

Blank Rome LLP

Examining and Dispelling Common Misconceptions about Suspension and Debarment

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Contractors are well aware that being suspended or debarred renders them ineligible for federal contracts and subcontracts. Many contractors may believe that suspension and debarment are not realistic risks for them if they...more

Cohen Seglias Pallas Greenhall & Furman PC

[Webinar] Organizational Conflicts of Interests (OCIs): What They Are and How Contractors Can Work with the Government to Mitigate...

OCIs can have a serious negative impact on contractors. If it is determined that an OCI exists, it can lead to a contractor being excluded from a contract competition, having an existing contract terminated, and, in some...more

Williams Mullen

Suspension and Debarment

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The government can suspend or debar an entity or individual for a host of actions or omissions, barring them from doing business with the government. A proactive strategy of self-examination, corrective action and engagement...more

Blank Rome LLP

Deficient Administrative Record Leads Federal Court to Vacate 15-Year Debarment

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A recent federal court decision vacating a staggering 15-year debarment based on shortcomings in the administrative record offers a glimmer of hope to contractors facing exclusion from federal programs, and reinforces the...more

Akin Gump Strauss Hauer & Feld LLP

Final Rule on the Fair Pay and Safe Workplaces Executive Order Revealed

Key Points - - While making some welcomed changes to the proposed rule, the final rule leaves many of the significant burdens and costs associated with requiring contractors and subcontractors to disclose various...more

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