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CAS Coverage And Indirect Costs

Client Alert | 1 min read | 03.31.06

A previous Bullet Point addressed a recent decision, AM General LLC, in which the ASBCA decided that a contract awarded pursuant to a partial waiver of the Truth in Negotiations Act was nevertheless covered by the Cost Accounting Standards and adopted a “benefit” test for determining the homogeneity of indirect cost pools under CAS 418. In their article entitled “Practitioner's Comment: “Benefit” Test for CAS 418 Homogeneity,” published in the March 8, 2006, Thomson West The Government Contractor (http://www.crowell.com/pdf/newsroom/GovtContractor_March06.pdf), Terry Albertson and Linda Bruggeman discuss both the legal and practical problems with the Board's CAS 418 analysis as well as the legal issues presented by the CAS Board's lengthy delay in implementing the CAS exemptions in FASA and FARA.

Insights

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....