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Back to the Future: Personnel Security Clearance Process Back on GAO “High-Risk List”

Client Alert | 1 min read | 02.05.18

On January 25, 2018, GAO returned the personnel security clearance process to the “High-Risk List” of federal programs needing substantial attention, citing the delayed and backlogged investigations queue, slow reform of the clearance process, and lack of investigation quality metrics. GAO found that: the backlog had grown to over 700,000 by September 2017; the NBIB has too few investigators to significantly reduce the backlog; and an inter-agency reciprocity policy is not yet completed. From 2005-2011, DoD’s clearance process was on the List due to similar issues. GAO had removed the program because DoD and OPM had taken steps to improve timeliness and develop quality metrics. The program’s return to the List comes just as Congress has transferred responsibility for investigations back from OPM to DoD under the FY 2018 NDAA. Having held numerous security clearance reform and oversight hearings over the past decade, Congress may not react well to this development.

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Client Alert | 6 min read | 11.25.25

Brussels Court Clarifies the EU’s SPC Manufacturing Waiver Regulation Rules

On November 13, 2025, the president of the French-speaking Brussels Enterprise Court ruled in the long-running battle between Sandoz and Regeneron about the correct interpretation of the EU’s Supplementary Protection Certificate (SPC) Manufacturing Waiver Regulation regarding exports to a non-EU market. The Brussels Court dismissed Regeneron’s claim that Sandoz had provided a defective notification and agreed with Sandoz’s interpretation of the Regulation....