DoD's Proposed Counterfeit Electronic Parts Rules Are Short on Details
Client Alert | 1 min read | 05.22.13
Following up on its publication of an instruction on counterfeit parts on May 16, DoD issued a long-expected proposed rule on counterfeit electronic parts avoidance, detection, and liability, with comments due by July 15. As discussed on our blog, the rule -- which applies only to CAS-covered prime contractors but will have a much broader impact on subcontractors and suppliers -- requires that business systems include DoD-approved avoidance and detection systems, but leaves the details of the newly required systems to be fleshed out, it would seem, by DCAA and/or DCMA, and, while it imposes potentially unlimited liability for counterfeit parts, it has an exceedingly narrow "safe harbor."
Contacts
Insights
Client Alert | 2 min read | 04.10.26
On April 7, 2026, six federal agencies (FBI, CISA, NSA, EPA, DOE, and U.S. Cyber Command – Cyber National Mission Force) published a joint advisory warning that Iranian-affiliated threat actors are targeting internet-facing OT devices, particularly PLCs. In some cases, the threat actors have caused operational disruptions and financial losses at U.S. critical infrastructure organizations by manipulating software files that contain configuration settings as well as showing false data on hardware and software dashboards and displays.
Client Alert | 4 min read | 04.10.26
FTC Issues Five-Year Strategic Plan: What Businesses Need to Know
Client Alert | 4 min read | 04.09.26
Client Alert | 2 min read | 04.09.26
OMB Issues New Policy on Federal IT Transparency and Acquisition Oversight


