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CAS-covered Contract Not "Affected" By Accounting Change

Client Alert | less than 1 min read | 07.03.07

In its first addressing of the definition of "affected contracts" under the CAS regulations in a situation that arises with surprising frequency, the ASBCA in Lockheed Martin Corp. (June 28, 2007), a case handled by Crowell & Moring, has held that a CAS-covered contract awarded before a change in accounting practice was disclosed and implemented, but completely repriced with full disclosure of the change, is not "affected" by the change and is not subject to price adjustment to reflect the impact of the change. The decision also includes guidance about the meaning of "desirable" changes that should be helpful to contractors.

Insights

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....