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It’s Time for a Raise! DoD Proposes to Increase CPSR Threshold

Client Alert | 1 min read | 06.11.19

On May 31, 2019, DoD issued a proposed rule, which would amend the Defense Acquisition Regulation Supplement (DFARS) to establish a DoD-specific Contractor Purchasing System Review (CPSR) threshold of $50M at DFARS 244.302, to be used in lieu of $25M threshold at FAR 44.302(a), which has remained unchanged since 1996. According to the Federal Register, it is estimated that, with this new threshold in place, DCMA ACOs can reduce the number of contractor reviews by approximately 20% (from around 667 to 534), which would reduce the burden on smaller contractors and allow a more efficient and effective use of CPSR resources to review larger contractors where more taxpayer dollars are at risk. Comments on the rule are due by July 30, 2019.

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Client Alert | 10 min read | 07.03.25

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

The Orders represent FinCEN’s first actions using new special measures authority under the Fentanyl Sanctions Act and FEND Off Fentanyl Act of 2024 (codified at 21 U.S.C. § 2313a) (the “Fentanyl Act”) and continue the Trump Administration’s broader efforts against transnational cartels and narcotics trafficking....