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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 | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....