3 Days For Contractor ARRA Comments
Client Alert | less than 1 min read | 10.13.09
On September 30, OMB issued interim guidance on reviewing reports submitted by contractors pursuant to the American Recovery and Reinvestment Act requirements. In addition to providing guidance on the scope of agency review, the memo sets forth a tight schedule for agency review and comment and gives contractors a three-day window to respond to agency comments, all of which will be made public on federalreporting.gov.
Insights
Client Alert | 2 min read | 05.14.26
On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert.
Client Alert | 4 min read | 05.14.26
Client Alert | 6 min read | 05.12.26
Client Alert | 5 min read | 05.12.26
NYDFS Ramps Up Health Care Cybersecurity Enforcement With $2.25 Million Settlement
