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New Certification of Iran Sanctions Compliance - for You and Your Subsidiaries

Client Alert | 1 min read | 10.06.10

On September 29, 2010, the FAR Council published an Interim Rule with request for comment implementing the requirement in the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA") that every contractor certify that neither it, nor any entity owned or controlled by the contractor, engages in any activity for which sanctions could be imposed under section 5 of CISADA, including, for example, sales of goods, services, or technology that could directly and significantly facilitate the maintenance or expansion of Iran's domestic production of refined petroleum products. While the CISADA sanctions extend to both U.S. and foreign persons -- and the FAR Council has extended the certification requirement as broadly as possible to include procurements of commercial items, COTS items, and those below the simplified acquisition threshold -- to avoid any conflict with the U.S.'s commitments under the WTO Agreement on Government Procurement and other free trade agreements, contractors furnishing only "designated country" end products under a contract subject to the Trade Agreements Act are exempted from the certification requirement.

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Client Alert | 10 min read | 07.01.25

Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers

On June 23, 2025, the Ninth Circuit issued a long-awaited decision in Island Industries Inc. v. Sigma Corp. affirming a $26M False Claims Act (“FCA”) judgment against the defendant importer.  Sigma had appealed the judgment after a jury found the company violated the FCA by failing to pay customs duties owed to U.S. Customs and Border Protection (“CBP”).  The Ninth Circuit’s decision addresses an important jurisdictional issue and illustrates the significant financial exposure importers can face under the FCA at a time of increased tariffs and enforcement by the government.  ...