FY2017 Suspension and Debarment Trends
Client Alert | 1 min read | 11.07.17
Crowell & Moring partner and former acting Air Force suspending and debarring official David Robbins published his annual examination of the government’s suspension and debarment statistics for the prior government fiscal year. The article, entitled Suspension and Debarment: FY 2017 By the Numbers ran in Law360 and may be accessed here. This article represents a deep dive into the raw suspension/debarment numbers listed on the System for Award Management and shows year-over-year trends not available on the government’s annual Interagency Suspension and Debarment Committee report. It covers agency-specific trends for excluding individuals, small businesses, traditional government contractors, and non-traditional government contractors.
Insights
Client Alert | 3 min read | 02.11.26
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates.
Client Alert | 4 min read | 02.11.26
Consolidated Appropriations Act Introduces Sweeping Reforms for Pharmacy Benefit Managers
Client Alert | 3 min read | 02.10.26
UK FCA Proposes New Sustainability Disclosure Rules for Listed Companies
Client Alert | 3 min read | 02.09.26
