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DCMA Details Oversight of Counterfeit Electronic Parts

Client Alert | less than 1 min read | 08.04.15

On July 6, 2015, DCMA issued Instruction 1205 that provides the framework the government will use to assess compliance with DFARS 252.246-7007 (May 2014), which requires certain contractors to design and deploy systems to avoid and detect counterfeit electronic parts. The instruction assigns roles and responsibilities for DCMA functions, establishes a risk-based approach that will drive the types of oversight and surveillance contractors can generally expect, and details the reporting that may occur if counterfeit materials or suspected counterfeit materials are identified.


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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...