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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 | 08.26.26

D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances

In a significant and unanimous ruling, the D.C. Circuit upheld the Environmental Protection Agency’s (“EPA”) final rule designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), denying the petitions of seven industry groups seeking to overturn that designation.[1] CERCLA, also known as the “Superfund Statute,” allows EPA to require potentially responsible parties to fund cleanup of hazardous substances....