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ASBCA Clarifies SOL on Interest Claims Under the Prompt Payment Act

Client Alert | 1 min read | 05.23.16

In Public Warehousing Co. (May 2, 2016), the Board held the CDA statute of limitations on a contractor’s claim for interest penalties under the Prompt Payment Act does not accrue until the government makes the underlying payment. Rejecting the government’s argument that the interest claim should accrue as soon as government fails to make the underlying payment, the Board held that, under the PPA, “the events that fix the government's alleged liability and allow a claim for interest penalties to be asserted do not occur until the government pays the underlying invoice without paying the interest penalty due.”

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....