For the New Year, Out with Origin but In with New Definitions of Source & Nationality
Client Alert | 1 min read | 01.11.12
In a final rule published yesterday (but not effective until February 6), USAID revamped its source, origin, and nationality rules applicable to procurement of goods and services purchased with Foreign Assistance Act (FAA) funds both to implement the 1993 amendments to the FAA and to keep pace with the globalized economy. The new regulations adopt a single, presumptively authorized geographic code 937 (which includes the United States, the cooperating or recipient country, and developing countries, exclusive of advanced developing countries and prohibited sources) and eliminate the “increasingly obsolete and difficult to apply” origin requirement, while changing the definitions of source and nationality to ensure that “fly-by-night” entities cannot be set up somewhere within the authorized geographic region to evade the restrictions.
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Client Alert | 4 min read | 11.18.25
DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes
On November 14, 2025, the U.S. Department of Justice (DOJ) announced a sweeping series of enforcement actions, including four guilty pleas and more than $15 million in civil forfeitures against the Democratic People’s Republic of Korea (DPRK or North Korea) for remote information technology (IT) worker schemes. These actions underscore the federal government’s escalating focus on the exposure of U.S. companies to North Korean IT worker infiltration, following a series of U.S. Government action against the DPRK.
Client Alert | 6 min read | 11.18.25
Client Alert | 2 min read | 11.14.25
Client Alert | 6 min read | 11.14.25
Microplastics Update: Regulatory and Litigation Developments in 2025
