News & Analysis as of August 7, 2025

Subcontractors

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The National Defense Authorization Act is a United States federal statute enacted each year to specify the budget and expenditures of the Department of Defense. The NDAA identifies which agencies are responsible for national defense, provides funding for those agencies and includes instructions on proper use of the funds. less -

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

Holland & Knight LLP on 4/24/2025

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

Key Takeaways from the Federal Government’s Proposed Rule Banning Certain Chinese-Origin Semiconductor Technology

Morrison & Foerster LLP on 5/17/2024

Earlier this month, the Federal Acquisition Regulatory Council (“FAR Council”) issued an advanced notice of proposed rulemaking (ANPR) to implement parts of Section 5949 of the National Defense Authorization Act (NDAA) for...more

New Year, (Potentially) New Definition for “Subcontract”

Sheppard Mullin Richter & Hampton LLP on 12/20/2023

In addition to prohibiting the flow-down of non-mandatory FAR/DFARS clauses (which we talk about here), the Department of Defense (“DOD”) Final Rule in connection with the Defense Federal Acquisition Regulation Supplement...more

Important NDAA Provisions for Contractors and Their Supply Chains

Wiley Rein LLP on 12/19/2023

On December 14, 2023, the House of Representatives passed the National Defense Authorization Act for Fiscal Year 2024 (NDAA), following the Senate’s passage a few days earlier. The President is expected to sign the NDAA into...more

Congressional, Executive, and Legal Developments for Government Contractors to Consider

Venable LLP on 1/6/2023

Each month, Venable's Government Contracts Group publishes a summary of recent legal developments of interest to the government contractor community. Regulatory Updates - The FAR Council has proposed to amend the FAR...more

Section 889(a)(1)(B): Five Things to Know About the Interim Rule and a Roadmap for Compliance

Akin Gump Strauss Hauer & Feld LLP on 8/5/2020

- Akin Gump is hosting a Webinar tomorrow, August 6, 2020, at 12:00 p.m. (EST) to discuss Section 889, the implementing regulations, and the grant and loan restrictions also effective August 13, 2020. - On July 14, 2020,...more

2019 NDAA Analysis: Enhancing IDIQs and Other Provisions

Holland & Knight LLP on 5/15/2019

Over the past several months, this blog has analyzed several key provisions of the Fiscal Year 2019 National Defense Authorization Act (NDAA) that impact government contractors. This post briefly summarizes a variety of other...more

Weekly Update Newsletter - March 2019 #5

PilieroMazza PLLC on 4/1/2019

GOVERNMENT CONTRACTING - The Office of the Under Secretary of Defense released a class deviation, effective immediately, that implements section 1006 of the National Defense Authorization Act for Fiscal Year 2019. The...more

Weekly Update Newsletter - September 2018 #2

PilieroMazza PLLC on 9/25/2018

SMALL BUSINESS ADMINISTRATION - House Small Business Committee Calls for a Status Update on FAR Revision of Limitations on Subcontracting. Last week, House Small Business Committee Chairman Steve Chabot and Ranking...more

Changes to Supply Chain Management and Commercial Item Contracting in FY 2018 NDAA

Pillsbury Winthrop Shaw Pittman LLP on 11/21/2017

For Department of Defense (DoD) acquisitions, the Conference Report for Fiscal Year 2018 NDAA includes provisions that simplify and others that complicate contractor responsibilities. Proposed supply chain diligence...more

Cross Your Heart and Hope to Die – New DFARS Clauses Target Counterfeit Electronic Parts

Sheppard Mullin Richter & Hampton LLP on 9/22/2016

On August 2, 2016, the Department of Defense (“DOD”) rolled out new requirements for defense contractors that provide electronic parts and assemblies containing electronic parts. The new rules impose significant risks on DOD...more

Weekly Update Newsletter - October 2015 #2

PilieroMazza PLLC on 10/12/2015

GOVERNMENT CONTRACTS - Federal Acquisition Regulation: Simplified Acquisition Threshold for Overseas Acquisitions - The Department of Defense, General Services Administration, and NASA have issued a proposed rule to...more

Federal Acquisition Regulation: Amendments to Strengthen Prohibitions Against Trafficking

Foley Hoag LLP on 2/3/2015

On January 29, 2015, the U.S. Government released a final rule amending the Federal Acquisition Regulation (“FAR”). The final rule reflects changes to proposed amendments originally released in September 2013. The...more

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