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31-Month Suspension of Affiliates Violates FAR

Client Alert | 1 min read | 07.06.12

In Agility Def. and Gov't Servs. (June 26), an Alabama District Court rejected the government's assertion that an agency's suspension of a government contractor is beyond judicial review and overturned the suspensions because they had exceeded 18 months, in violation of FAR 9.407-4(b). The two plaintiffs were suspended in November 2009 based on their affiliation with an indicted contractor, Public Warehousing Company, and, although the initial suspension of the affiliates was proper, the agency could not extend the suspensions of the affiliates beyond 18 months because legal proceedings had not been initiated against the affiliates themselves.


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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....