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Go Ahead and Offer the Senator a Cup of Coffee

Client Alert | less than 1 min read | 02.21.08

As detailed in the attached bullet analysis, the Senate Select Committee on Ethics, in response to the Honest Leadership and Open Government Act of 2007 (“HLOGA”), published new guidance concerning the gift exceptions for items of little intrinsic value and food offered other than as part of a meal. Although the Senate clarifications arguably clear up very little, they are a good reminder that it is time to update company codes of conduct and compliance manuals in light of the many new requirements established by HLOGA.

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...