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Are Your GSA Schedule Products TAA-Compliant?

Client Alert | 1 min read | 10.08.14

While Multiple Award Schedules administered by GSA can be a valuable tool for selling to government customers, these government-wide contracts include numerous special requirements, including the requirement that each and every product offered comply with the Trade Agreements Act restriction on providing products from so-called "non-designated countries." In "Where Are Your Products From? The Importance and Challenges of Managing TAA Compliance for GSA Schedule Holders", published in Bloomberg BNA Federal Contracts Report, C&M's Cathy Kunz and Addie Cliffe discuss recent enforcement actions that highlight the risk of TAA non-compliance and offer practical pointers for assuring compliance.


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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....