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Annual ISDC Reporting

Client Alert | less than 1 min read | 11.07.19

The annual Interagency Suspension and Debarment Committee recently issued its annual report to Congress. The report, found here, contains details of the state of the federal suspension and debarment program for Fiscal Year 2018 (note the significant timelag). The report notes a focus on cybersecurity contractor compliance issues, and proposals to modernize/streamline lead agency coordination. Otherwise, total numbers of suspensions, proposed debarments, and debarments continued to decline year-over-year, while pre-notice interactions with contractors continued to comprise a significant portion of SDO offices’ dockets.

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Client Alert | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....

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