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CAS Exemption For Time & Material And Labor Hour Contracts

Client Alert | less than 1 min read | 07.06.07

To conform the Cost Accounting Standards regulations to the statutory provisions of the Services Acquisition Reform Act and to the recently amended provisions of the FAR, the CAS Board has issued regulations (72 Fed. Reg. 36367, July 3, 2007) exempting Time and Material (T&M) and Labor Hour (LH) contracts for commercial items from CAS coverage. Because the comparable FAR provisions require competition as a prerequisite to award of T&M and LH contracts for commercial items, the CAS exemption will apply only to competitively awarded contracts.

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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....