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Agency Can't Ignore Obvious Costs In Evaluation

Client Alert | less than 1 min read | 04.18.05

While agencies are given latitude in establishing evaluation criteria, an agency cannot rationally fail to include costs it knows will be involved in the procurement. The Court of Federal Claims in Arch Chemicals, Inc. v. U.S. (Mar. 18, 2005) instructed that the agency unreasonably excluded from the evaluation plant shutdown costs it was obligated to pay the incumbent if it awarded to another company.

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Client Alert | 10 min read | 07.03.25

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

The Orders represent FinCEN’s first actions using new special measures authority under the Fentanyl Sanctions Act and FEND Off Fentanyl Act of 2024 (codified at 21 U.S.C. § 2313a) (the “Fentanyl Act”) and continue the Trump Administration’s broader efforts against transnational cartels and narcotics trafficking....