25th Anniversary Version Of FMF Guidelines -- No Celebration For It Companies
Client Alert | less than 1 min read | 09.10.09
On August 31, 2009, the Defense Security Cooperation Agency released a revised set of Guidelines for Foreign Military Financing of Direct Commercial Contracts and Contractor's Certification & Agreement with DSCA which are to be implemented no later than October 1, 2009. The principal changes focus on the difficult compliance issue of identifying non-U.S. content in the products and underscore DSCA's increasingly inflexible approach to that issue, including determination whether spares and post-delivery warranty or maintenance effort constitute non-U.S. content ineligible for financing, a problem that has been particularly troubling for companies furnishing information technology products to the Government of Israel under the FMF program.
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Client Alert | 3 min read | 09.13.24
SEC Disbands its Climate and ESG Enforcement Task Force
The Securities and Exchange Commission (SEC) has reportedly recently dissolved its Climate and ESG Enforcement Task Force (the Task Force). The Task Force was part of SEC Chair Gary Gensler’s broader push to increase investors’ access to environmental, social, and governance (“ESG”) information about public companies and registered investment companies. The dissolution of the Climate and ESG Enforcement Task Force comes after three years marked by industry resistance and a mixed record in the courts. Prior to the Task Force’s dissolution, the agency removed ESG from its annual Examination Priorities Report, which provides areas of particular focus during SEC examinations. While the Task Force has been dissolved, the SEC is still pursuing a number of its proposed ESG and climate-related rules.
Client Alert | 12 min read | 09.13.24
Tri-Agencies Finalize NQTL Comparative Analysis Standards in Final Rule
Client Alert | 5 min read | 09.11.24
Client Alert | 3 min read | 09.11.24
