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GAO Rejects Cooperative Agreements Dodge

Client Alert | less than 1 min read | 08.27.12

On August 15, 2012, GAO sustained a protest by several housing agencies challenging HUD's attempt to obtain services through cooperative agreements, finding that HUD improperly avoided the procurement laws and should have awarded a contract. GAO's ruling serves as a reminder that agencies cannot avoid CICA requirements by using cooperative agreements (or inter/intra-agency agreements, which have also received recent attention for possible abuse) to avoid the competitive procurement laws.

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Client Alert | 5 min read | 02.23.26

UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations

The UK’s Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence concerning the "ownership and control" test within UK financial sanctions. The call for evidence, running until 11:59 p.m. on 13 April 2026, seeks stakeholder views on the challenges and implementation of the "control" limb, with particular focus on its hypothetical element....