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 | 05.01.26
Federal Court Blocks Trump Administration Policies Restricting Wind and Solar Permitting
A coalition of regional clean energy trade associations — including RENEW Northeast, Alliance for Clean Energy New York, Southern Renewable Energy Association, and Interwest Energy Alliance — along with the Green Energy Consumers Alliance (GECA), filed suit in December 2025 against the Department of the Interior (DOI), the Bureau of Land Management, the Bureau of Ocean Energy Management, the U.S. Fish and Wildlife Service (USFWS), and the Army Corps of Engineers. The complaint alleged that five agency actions, issued in response to a series of executive orders and presidential memoranda beginning on January 20, 2025, violated the Administrative Procedure Act (APA) by arbitrarily halting or restricting federal permitting for wind and solar energy projects. Plaintiffs sought a preliminary injunction to halt enforcement of these policies while the litigation proceeds. See Renew Northeast, et al. v. U.S. Dep’t of Interior, et al., No. 25-cv-13961-DJC, (D. Mass. Apr. 21, 2026) ECF Dkt. 89.
Client Alert | 2 min read | 05.01.26
New Executive Order Promoting Fixed Price Contracting: What It Means for Federal Contractors
Client Alert | 8 min read | 05.01.26
Pre-Approved: ICO Publishes Guidance on "Recognised Legitimate Interests”
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
