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DoD Tightens Counterfeit Prevention Policy

Client Alert | less than 1 min read | 05.02.13

On April 26, 2013, DoD issued an Instruction to establish policies to prevent the introduction of counterfeit material at any level of the DoD supply chain and to seek restitution for critical failures and damages caused by such material. DoD component heads are tasked with integrating the policy into contract requirements and procedures, procuring critical material only from suppliers that meet appropriate counterfeit avoidance criteria or applying additional risk management measures when such suppliers are not available, using sampling techniques and material testing for detection, and reporting all suspected or confirmed occurrences.

 

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...