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E-Verify -- Immigration Enforcement Comes to Federal Contracting

Client Alert | 1 min read | 11.14.08

On November 14, 2008, the FAR Council issued a new rule and contract clause, effective January 15, 2009, requiring most federal contractors and subcontractors to use the Department of Homeland Security's E-Verify system to verify the employment eligibility of all new hires in the United States and all employees working in the United States on federal contracts and subcontracts. The contract clause will apply to all new federal contracts for more than $100,000 (except for very limited contracts for commercially available off-the-shelf items sold in substantial quantities in the commercial marketplace) and subcontracts for services or construction in excess of $3000 and includes a specific provision requiring referral for potential suspension or debarment for failure to comply with the rules governing the E-Verify program.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

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