25th Anniversary Version Of FMF Guidelines -- No Celebration For It Companies
Client Alert | less than 1 min read | 09.10.09
On August 31, 2009, the Defense Security Cooperation Agency released a revised set of Guidelines for Foreign Military Financing of Direct Commercial Contracts and Contractor's Certification & Agreement with DSCA which are to be implemented no later than October 1, 2009. The principal changes focus on the difficult compliance issue of identifying non-U.S. content in the products and underscore DSCA's increasingly inflexible approach to that issue, including determination whether spares and post-delivery warranty or maintenance effort constitute non-U.S. content ineligible for financing, a problem that has been particularly troubling for companies furnishing information technology products to the Government of Israel under the FMF program.
Contacts
Insights
Client Alert | 7 min read | 08.17.26
Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule
After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen.
Client Alert | 4 min read | 08.14.26
License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations
Client Alert | 4 min read | 08.13.26
Supreme Court Confirms Contractual Loss of Bargain Without Repudiatory Breach
Client Alert | 7 min read | 08.12.26
Developments in Canadian Investment Treaty Practice: New FIPA Between Canada and UAE in Force
