1. Home
  2. |Insights
  3. |Decision Signals Increased SBA Scrutiny of Size Status

Decision Signals Increased SBA Scrutiny of Size Status

Client Alert | 1 min read | 04.16.07

In Size Appeal of Ross Aviation, Inc., SBA No. SIZ-4840, March 07, 2007, the SBA’s Office of Hearings and Appeals (“OHA”) reversed its earlier decision in Size Appeal of Spectrum Landscape Services, Inc., SBA No. SIZ-4313 (1998), and expanded the scope of its review. Basing its reversal of position on the objective of promoting the integrity of the procurement process, OHA held that “[a]part from contract-specific issues (e.g., ostensible subcontractor and non-manufacturer rule), OHA will no longer dismiss automatically an unsuccessful offeror’s appeal as moot after contract award . . . simply because of a contracting officer’s representation that he/she intends not to disturb award of the contract (including their intent to award options).”

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....