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National Archives Issues Non-FAR-Based Guidance for Controlled Unclassified Information

Client Alert | 1 min read | 02.13.18

The Information Security Oversight Office (ISOO) within the National Archives and Records Administration (NARA) has issued guidance relevant to contractors and other non-executive branch entities concerning controlled unclassified information (CUI). Specifically, the ISOO issued CUI Notice 2018-01 regarding information sharing agreements with non-executive branch entities that are not governed by the forthcoming CUI Federal Acquisition Regulation (FAR) Clause, including certain contracts, grants, licenses, and memoranda of understanding. Importantly, the ISOO guidance provides both mandatory and recommended language for inclusion in future information sharing agreements to help ensure the appropriate handling and safeguarding of CUI. While we continue to await a proposed FAR Clause regarding CUI, contractors should benefit from the additional clarity that this ISOO guidance brings in standardizing CUI provisions for non-FAR based agreements.

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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:...