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GAO Rules that DoD May Not Require a Small Business Joint Venture Itself to Hold Facility Clearance

Client Alert | 1 min read | 09.08.21

In InfoPoint LLC, the Government Accountability Office ruled that the Department of Defense could not require a small business joint venture offeror to itself hold a facility clearance when the individual joint venture members themselves both hold the necessary facility clearances.  GAO ruled that the National Defense Authorization Act for Fiscal Year 2020, implemented in the Small Business Administration’s regulations at 13 C.F.R. § 121.103(h)(4), unambiguously prohibits the DoD from requiring that a joint venture hold a facility clearance if the members do.  Read more about this decision here.

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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....