DoD Broadens Allowability for Cost Associated with Counterfeit Electronic Parts
Client Alert | 1 min read | 09.01.16
On August 30, 2016, DoD published a final rule that expands allowability of costs of actual or suspect counterfeit electronic parts and the cost of rework or corrective action due to their use. Whereas, previously, such costs were only allowable if the parts were government-furnished property, effective August 30, 2016, such costs will also be allowable if the parts are obtained in accordance with the newly added DFARS 252.246-7008 concerning sourcing of electronic parts; the contractor becomes aware of the part through inspection, testing, authentication, or other means; and it provides notice to the cognizant COs and GIDEP within 60 days of becoming aware.
Contacts
Insights
Client Alert | 2 min read | 05.14.26
On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert.
Client Alert | 4 min read | 05.14.26
Client Alert | 6 min read | 05.12.26
Client Alert | 5 min read | 05.12.26
NYDFS Ramps Up Health Care Cybersecurity Enforcement With $2.25 Million Settlement
