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Eleventh Circuit OK’s Suspension of Affiliates Beyond 18 Months

Client Alert | 1 min read | 01.08.14

In Agility Def. & Gov’t Servs. v. Dep’t of Def. (Dec. 31, 2013), the Eleventh Circuit reversed the judgment below and held that when an agency suspends a contractor it may suspend affiliates of that contractor for greater than 18 months based solely on their affiliation provided legal proceedings have been initiated during that period against the contractor. The district court had held that the regulations required affiliation-based suspensions to be lifted after 18 months unless legal proceedings had been initiated against the affiliates themselves, but the Eleventh Circuit held that affiliates are afforded sufficient due process and that no independent showing of wrongdoing by an affiliate is required for suspension or debarment.


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Client Alert | 10 min read | 07.03.25

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

The Orders represent FinCEN’s first actions using new special measures authority under the Fentanyl Sanctions Act and FEND Off Fentanyl Act of 2024 (codified at 21 U.S.C. § 2313a) (the “Fentanyl Act”) and continue the Trump Administration’s broader efforts against transnational cartels and narcotics trafficking....