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Christian Doctrine Applied to Subcontract

Client Alert | 1 min read | 04.05.13

As discussed in more detail in a Crowell Alert issued today, the U.S. District Court for D.C. in UPMC Braddock v. Harris (Mar. 30, 2013) relied on the Christrian doctrine, a rule derived from case law that allows for the inclusion in a contract by operation of law of omitted government contract clauses expressing a significant public procurement policy, to incorporate affirmative action clauses into a subcontract between certain hospitals and a managed care organization with a Federal Employees Health Benefits Program prime contract. This is the first instance of which we are aware that a court has used the Christian doctrine to incorporate federal procurement obligations into a subcontract.


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Client Alert | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....