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New "600 Series" Export Classification Brings No Relief from Offset Reporting

Client Alert | 1 min read | 12.09.15

On December 2, 2015, Commerce's Bureau of Industry & Security (BIS) published a proposed rule clarifying that annual reporting of offset arrangements exceeding $5 million associated with sales of defense articles or services will include sales of items now classified within any "600 Series" of the Commerce Control List, except for certain submersible or semi-submersible cargo transport vehicles. This proposed rule expands the range of sales that can trigger offset reporting by expressly including sales of various "600 Series" items (e.g., military helmets) that were previously controlled under other Export Control Classification Numbers within the Export Administration Regulation and, thus, not subject to the offset reporting obligations mandated by 15 C.F.R. Part 701.


Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....