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FAR Council Finalizes Reporting Requirements for Executive Compensation and First-Tier Subcontract Awards

Client Alert | less than 1 min read | 07.26.12

On July 26, 2012, the FAR Council issued a final rule requiring certain contractors to report executive compensation, first-tier subcontract awards, and executive compensation information for first-tier subcontractors for public release on the USASpending website. While the final rule is very similar to the interim rule issued on July 8, 2010, there is a substantive change to the definition of first-tier subcontract, and the preamble to the final rule contains extensive commentary to guide the implementation of the rule, including discussion of the application of the public company exemption.

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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” ...