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Congress Enacts Appropriations Restriction Relating to Felony Convictions

Client Alert | 1 min read | 01.18.12

As is discussed in more detail in a blog posting, the recently enacted Consolidated Appropriations Act of 2012 includes provision in five of the nine individual bills covered in the Act prohibiting the use of funds “to enter into a contract, memorandum of understanding, or cooperative agreement with, make a grant to, or provide a loan or loan guarantee to, any corporation” with a felony conviction within the preceding 24 months, unless the agency has considered suspension or debarment and made a determination that no further action is necessary. This provision is almost sure to create uncertainty because Congress did not create a uniform standard, but instead included language in only certain individual appropriation acts, with substantial variances between the different provisions (e.g., some provisions only apply if the corporation is convicted while other also include officers or agents of the corporation).


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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....