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.
Contacts
Insights
Client Alert | 4 min read | 12.08.25
California’s AB 2013 Requires Generative AI Data Disclosure by January 1, 2026
California continues its blistering pace in enacting artificial intelligence regulations. In 2024 alone, California enacted 18 AI-related bills seeking to regulate AI tools and increase transparency around AI data disclosure.
Client Alert | 4 min read | 12.04.25
District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products
Client Alert | 21 min read | 12.04.25
Highlights: CMS’s Proposed Rule for Medicare Part C & D (CY 2027 NPRM)

