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Compounding The Problem

Client Alert | 1 min read | 09.24.10

On September 22, 2010, the Civilian Agency Acquisition Council and Defense Acquisition Regulations Council issued a proposed rule that would amend the FAR to require compound, rather than simple, interest to be used in calculating damages for violations of the Truth in Negotiations Act (TINA). The proposal follows the problematic analysis in Gates v. Raytheon, 584 F.3d 1062 (Fed. Cir. 2009), which held that, because the Cost Accounting Standards (CAS) statute requires interest on cost impacts for CAS violations to be calculated at the rate established under 26 U.S.C. § 6621, the same rate referenced in the TINA statute, the interest must be compounded in accordance with 26 U.S.C. § 6622, even though the CAS statute does not refer to or incorporate § 6622 by reference.

Insights

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....