Wake-up Call: GSA Launches Requirement for Schedule Contractors to Reaffirm TAA Compliance
Client Alert | less than 1 min read | 05.06.16
Concerned with repeated instances of FOIA requests and congressional inquiries exposing contractors offering products not compliant with the Trade Agreements Act on their Federal Supply Schedule contracts, on May 5, 2016, GSA began notifying several contractors that, within five business days, they would need to provide certification that products offered were TAA-compliant or remove them from their offering. The breadth of this initiative continues to unfold, but it serves as a caution for contractors to reevaluate their supply chain and the manner in which they offer products on their FSS contracts under the complex “substantial transformation” rules for establishing country-of-origin under the TAA.
Contacts
Insights
Client Alert | 3 min read | 11.21.25
On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
Client Alert | 3 min read | 11.20.25
Client Alert | 3 min read | 11.20.25
Client Alert | 6 min read | 11.19.25
