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31-Month Suspension of Affiliates Violates FAR

Client Alert | 1 min read | 07.06.12

In Agility Def. and Gov't Servs. (June 26), an Alabama District Court rejected the government's assertion that an agency's suspension of a government contractor is beyond judicial review and overturned the suspensions because they had exceeded 18 months, in violation of FAR 9.407-4(b). The two plaintiffs were suspended in November 2009 based on their affiliation with an indicted contractor, Public Warehousing Company, and, although the initial suspension of the affiliates was proper, the agency could not extend the suspensions of the affiliates beyond 18 months because legal proceedings had not been initiated against the affiliates themselves.


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Client Alert | 10 min read | 03.16.26

Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold....