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Ban on Contractor Political Contributions Upheld

Client Alert | less than 1 min read | 07.13.15

In Wagner v. FEC (July 7, 2015), the D.C. Circuit upheld the seventy-five-year-old ban on political donations by individual contractors to federal candidates and political parties. Despite the First Amendment and equal protection arguments the plaintiffs raised, the court held that the compelling interests that support the contribution ban – protection against quid pro quo corruption and defense of merit-based public administration – are "neither theoretical nor antiquated, but rather are grounded in unhappy experience stretching to the present day."


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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....