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Eleventh Circuit OK’s Suspension of Affiliates Beyond 18 Months

Client Alert | 1 min read | 01.08.14

In Agility Def. & Gov’t Servs. v. Dep’t of Def. (Dec. 31, 2013), the Eleventh Circuit reversed the judgment below and held that when an agency suspends a contractor it may suspend affiliates of that contractor for greater than 18 months based solely on their affiliation provided legal proceedings have been initiated during that period against the contractor. The district court had held that the regulations required affiliation-based suspensions to be lifted after 18 months unless legal proceedings had been initiated against the affiliates themselves, but the Eleventh Circuit held that affiliates are afforded sufficient due process and that no independent showing of wrongdoing by an affiliate is required for suspension or debarment.


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Client Alert | 3 min read | 11.12.25

EPA Proposes Important Revisions to its PFAS Reporting Regulations

On November 10, 2025, the U.S. Environmental Protection Agency (EPA) released proposed regulations that, if adopted, would substantially alter the reporting obligations of companies that manufacture or import products containing per- or polyfluoroalkyl substances (PFAS). The proposed regulations would significantly reduce reporting burdens by exempting numerous products that currently trigger reporting requirements under EPA’s PFAS reporting regulations.  The proposed regulations would also delay the current deadline for reporting....