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In 2025, the U.S. Government’s policy statements and Executive Orders have had far-reaching impacts for government contractors and grant recipients. Although terminations, stop work orders, and de-scopes have affected private companies, non-profits, and universities doing business across multiple agencies, the U.S. Government’s policies relating to the U.S. Agency for International Development (USAID) has caused particular confusion and uncertainty relating to performance, compliance, and contractual procedure. Key questions have included the potential impacts of official and less formal communications from the U.S. Government, procedural issues arising from the move of certain functions to the U.S. Department of State, and the effect of various pending litigations. As businesses and organizations plan for 2026, the importance of preserving their rights and maximizing potential recovery opportunities remains paramount.

Caroline E. Brown, a partner in our White Collar and Regulatory Enforcement and International Trade groups, will moderate discussions on compliance with economic sanctions and the U.S. Department of the Treasury’s restrictions on outbound investment at the American Conference Institute's 15th Annual New York Forum on Economic Sanctions.  On December 3 and 4, respectively, Brown will moderate a roundtable entitled "Cross-Functional Collaboration: Strategies for Clear Communication and Training Across Functions and Jurisdictions" and a panel entitled "The Rise of Outbound Investment Rules and the Intersection with Sanctions and Export Controls: New Legal and Compliance Considerations Affecting Transactions."