Adelicia R. Cliffe
Overview
Addie Cliffe helps companies in a broad range of industries — from professional services, software, and technology to traditional defense contracting — navigate the complex requirements around doing business with the U.S. government, with a particular focus on cross-border and national security issues. In addition, Addie advises clients on regulatory issues related to foreign investment in the United States, representing clients with respect to national security reviews by the Committee on Foreign Investment in the United States (CFIUS) and measures to mitigate foreign ownership, control, or influence (FOCI mitigation).
Career & Education
- Georgetown University School of Foreign Service, B.S., 1998
- The George Washington University Law School, J.D., with high honors, The Order of the Coif, 2006
- District of Columbia
- Maryland
- French
- Spanish
Adelicia is extremely knowledgeable in many areas of government contracting and always has great advice and judgment in tricky situations. She is extremely responsive and always knows how to get us the right answer.
— Chambers USA
Addie's Insights
Client Alert | 3 min read | 04.26.24
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018. The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:
Client Alert | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
Client Alert | 1 min read | 04.15.24
New FAR Part 40 to Address Supply Chain and Information Security Requirements
Representative Matters
Government Contracts Counseling
- Assisted clients in the development, enhancement, and implementation of compliance programs.
- Provided on-site training for companies on a range of issues, including ethics and compliance issues and basics of government contracting.
- Counseled clients regarding mandatory disclosure obligations and related regulatory reporting processes.
- Assisting clients in obtaining and maintaining facility clearances and compliance with the National Industrial Security Program regulations, including issues around the mitigation of foreign ownership, control, or influence (FOCI).
- Counseled clients on issues related to supply chain security and sourcing restrictions.
- Counseled clients on compliance with the Buy American Act, Trade Agreements Act, and other domestic preference regimes (e.g., the various Department of Transportation agencies’ Buy America requirements, the IIJA Buy America requirements, domestic content requirements applicable to Foreign Military Financing).
- Counseled clients on compliance with GSA Schedule compliance issues.
Government Contracts Due Diligence and Transactions
- Performed government contracts and international trade diligence, for both buyers and sellers, representing government contractors in a range of industries, such as Accenture Federal Services and HP Company.
- Advised clients on special regulatory requirements related to cross-border investment and national security matters, including reviews conducted by the Committee on Foreign Investment in the United States (CFIUS), compliance with the National Industrial Security Program and mitigation of Foreign Ownership, Control, or Influence (FOCI mitigation).
- Provided guidance on government contracts and trade issues in the integration of newly acquired companies into the buyer’s organization, such as the execution of novation agreements and the transfer of export authorizations.
Government Contracts Litigation and Investigations
- Assisted contractors in performing internal investigations and defending against Government investigations into various compliance issues (e.g., non-compliance with domestic preferences, special requirements related to FMF-funded contracts, GSA Schedule pricing requirements).
- Assisted contractors in drafting and settling voluntary, directed, and mandatory disclosures.
- Assisted clients in bringing claims against government customers, responding to cure notices, and defending against terminations for default.
- Represented contractors in investigations related to the civil False Claims Act.
Addie's Insights
Client Alert | 3 min read | 04.26.24
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018. The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:
Client Alert | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
Client Alert | 1 min read | 04.15.24
New FAR Part 40 to Address Supply Chain and Information Security Requirements
Practices
- Government Contracts
- Government Contracts Transactions, M&A and Diligence
- Supply Chain Security and Risk Management
- International Trade
- WTO, FTAs and Market Access
- Export Controls
- Committee on Foreign Investment in the United States (CFIUS)
- Government Contracts Compliance
- Claims and Disputes Litigation
- Government Contracts Investigations
- False Claims Act Defense
- Government Contracts Transactions
- Inflation Reduction Act
- National Security
- Supply Chain Management
- Regulatory Litigation
- International Trade Investigations
Addie's Insights
Client Alert | 3 min read | 04.26.24
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018. The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:
Client Alert | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
Client Alert | 1 min read | 04.15.24
New FAR Part 40 to Address Supply Chain and Information Security Requirements