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With More to Come, DoD Expands Reach of Detection and Avoidance of Counterfeit Parts Requirements

Client Alert | 1 min read | 08.02.16

Today, DoD published a final rule further – but still only partially – implementing the FY12 DoD Authorization Act requirement (since amended) for detection and avoidance of counterfeit electronic parts by imposing on all contractors and subcontractors, including small businesses and suppliers of COTS products and commercial items, traceability obligations and procedures for identifying “contractor approved sources” when electronic parts are unavailable from the original manufacturer or other source identified in the new clause (DFARS 252.246-7008). The new clause also provides for specific procedures to be followed, including notifying DoD and performing authentication, inspection, and testing to industry standards when electrical parts are obtained from subcontractors that refuse flowdown of the clause or from sources other than those expressly authorized under the clause.

Insights

Client Alert | 4 min read | 09.12.25

SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal

On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A....