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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.

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Client Alert | 3 min read | 03.12.26

DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy

On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”...