Executive Order 14042 Agency Class Deviation Guidance, A Side-by-Side Comparison
Client Alert | 1 min read | 10.08.21
Executive Order 14042, issued on September 9, 2021, requires that certain federal contractors and subcontractors mandate vaccinations against COVID-19 for covered employees in addition to requiring compliance by covered employees and visitors with other COVID-19 safety protocols.
However, E.O. 14042 leaves several questions unanswered, including how agencies should implement the order and, in some cases, what types of contracts are covered. Government agencies have begun to issue guidance in the form of class deviations, the substance of which we are providing as a side-by-side comparison.
Crowell & Moring LLP is tracking this emerging guidance, and is pleased to present this table, current as of the date on the table.
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Client Alert | 4 min read | 05.18.26
(Not) All’s Weld That Ends Weld: Duty Evasion Scheme Ends in Historic $549.5M FCA Settlement
The Department of Justice (DOJ) and the cross-agency Trade Fraud Task Force have upped the ante by an order of magnitude in the government’s pursuit of customs fraud. On May 1, 2026—only a few months after setting its previous record-high customs-related False Claims Act (FCA) settlement of $54.4 million with Ceratizit USA, LLC—the DOJ shattered that record with a $549.5 million settlement with Perfectus Aluminum Inc., its subsidiary Perfectus Aluminum Acquisitions LLC, and a set of four affiliated warehousing companies. The Perfectus settlement resolves allegations that the defendants violated the FCA by evading antidumping and countervailing duties (AD/CVD). The settlement resolves three separate qui tam complaints filed by two individual relators and the Aluminum Extruders Council, an international industry association. Defendants were previously criminally convicted on charges related to the same scheme, and those convictions were affirmed by the Ninth Circuit in 2024.
Client Alert | 7 min read | 05.18.26
Client Alert | 6 min read | 05.18.26
Seventh Circuit Opens the Door on Loyalty Program Tax Exclusions
Client Alert | 5 min read | 05.18.26
The Hidden Ingredient Problem: PFAS Litigation and Regulation Are Reshaping the Beauty Industry







