On June 29, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) launched an online Reconsideration Portal for requests to remove persons or property from OFAC sanctions lists, including the Specially Designated Nationals and Blocked Persons (SDN) List. OFAC states that the portal streamlines delisting petitions by collecting key information upfront rather
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DOJ Issues First Corporate Enforcement Policy Declination: Lessons from Bosch’s FDPR Export Control Resolution
On June 17, the U.S. Department of Justice (DOJ) National Security Division (NSD) announced its first declination under the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), declining to prosecute Robert Bosch GmbH (Bosch) for potential criminal violations of the Export Control Reform Act (ECRA).
Procurement Fraud Enforcement Trends Continue Into 2026
As procurement fraud enforcement continues to be a priority for the Department of Justice and other federal agencies, we take a look back at significant 2025 enforcement developments affecting government contractors, grant recipients and participants in federal programs in our 2025 Procurement Fraud Review.
FinCEN Proposed Rulemaking: Significant Revisions Centered on Risk, Effectiveness, and Supervisory Consistency
On April 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Press Release describing a Notice of Proposed Rulemaking that would significantly reshape anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements across a wide range of financial institutions. Comments are due by June 9, 2026.
Clarified Standard for Challenging CICA Stay Overrides
On April 15, the Federal Circuit issued a decision clarifying the burden a protestor must meet when challenging an agency’s override of the Competition in Contracting Act’s (CICA) automatic stay of performance. In Life Science Logistics, LLC v. United States, the court held that when challenging an override of CICA’s automatic stay of performance
SBIR/STTR Reauthorization Brings New Opportunities and New Diligence Expectations
After a brief lapse, Congress has reauthorized the Small Business Innovation Research and Small Business Technology Transfer programs through Fiscal Year 2031. President Trump signed the Small Business Innovation and Economic Security Act, S. 3971, into law on April 13, 2026. The legislation restores certainty to two of the federal government’s most important funding
President Trump Issues Executive Order Directing Agencies to Default to Fixed-Price Contracting
On April 30, President Trump issued an Executive Order (Order) directing federal agencies to make fixed-price contracting the default and preferred procurement method across the federal government. The Order reflects the administration’s view that fixed-price contracts better promote cost predictability, contractor accountability, and performance-based outcomes than cost-reimbursement and other non-fixed-price contract types.
FAR Council Moves Quickly on DEI Executive Order, Which Has Already Been Challenged in District Court
On April 17, the Federal Acquisition Regulatory (FAR) Council issued guidance implementing Executive Order (EO or Order) 14398, Addressing DEI Discrimination by Federal Contractors, less than 30 days after the Order was signed and well ahead of the 60-day deadline the Order gave the Council to act. Because the Order required agencies to begin implementation
FTC Signals Renewed “Made in USA” Enforcement Focus Following Trump Executive Order
Recent “Made in USA” enforcement actions show that U.S.-origin claims continue to be an active enforcement priority for the Federal Trade Commission (FTC). On April 14, the FTC announced three enforcement actions and the closure of two investigations involving companies alleged to have overstated the domestic origin of their products. The announcement followed a March
Export Compliance in Line with Recent BIS Civil Penalty
We co-authored an article for Corporate Compliance Insights discussing a recent case in which the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a penalty against Applied Materials (AMAT) for $253 million, the second-largest civil penalty in BIS history.