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.
Contacts
Insights
Client Alert | 10 min read | 03.16.26
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold.
Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy



