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It’s Back – DCAA’s Non-Defense Audit Authority Revived

Client Alert | less than 1 min read | 11.03.16

A recent DCAA policy memorandum lifted the moratorium on DCAA performing non-Defense audits, which (as discussed here) effectively applied only to incurred cost audits. Specifically, because DCAA has purportedly "met the requirement of less than 18 months of incurred cost inventory" outlined in the 2016 National Defense Authorization Act as of October 1, 2016, DCAA "may again provide full audit support for non-Defense agencies" and the Operations Directorate "has coordinated at the Executive level with [its] reimbursable customers to inform them that [its] audit services can resume."

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Client Alert | 7 min read | 05.27.26

Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act

Colorado’s original AI Act (SB 24-205), signed in May 2024, imposed broad obligations on developers and deployers of “high-risk AI systems” — including requiring risk management programs, impact assessments, and affirmative steps to prevent algorithmic discrimination across employment, housing, lending, insurance, health care, and education decisions. The operative date for SB 24-205 was extended twice, and a court temporarily suspended enforcement in early 2026, following a lawsuit filed by xAI, which the U.S. Department of Justice (DOJ) intervened to support. Industry feedback on SB 24-205 was generally negative. In response to this environment, Colorado’s legislature undertook a rewrite, drafting and passing SB 26-189 in a matter of weeks. SB 26-189 reflects the legislature’s effort to preserve the policy goal of filling the AI oversight vacuum given the lack of a comprehensive federal law, but within a more workable compliance framework....

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