CFC’s Transfer to CBCA Not Constrained by Board’s 90-Day Appeal Period
Client Alert | 1 min read | 10.06.16
In Appeal of Suffolk Constr. Co., the CBCA accepted the transfer of an appeal from the CFC to the CBCA, where the contractor had several pending appeals relating to the same contract, despite the fact that the CFC appeal was not filed within CBCA’s 90-day appeal period after the final decision. GSA argued that the CBCA lacked jurisdiction because it was filed after the 90 days had run (but before the CFC’s one-year appeal period), but the board held that – when “2 or more actions aris[e] from one contract” – the requirement for initiating a timely board appeal did not constrain the CFC’s authority to transfer to the board an action over which the CFC concededly had jurisdiction.
Insights
Client Alert | 10 min read | 07.03.25
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.
Client Alert | 4 min read | 07.02.25
Client Alert | 4 min read | 07.02.25