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Enhanced Requirements for Cost-Reimbursement Contracting

Client Alert | 1 min read | 03.16.11

As required by the FY 2009 DOD Authorization Act, the Federal Acquisition Regulation has been amended effective March 16, 2011 (76 Fed. Reg. 14543), to add new provisions controlling the Government's decision to award cost-reimbursement contracts. The enhanced regulations focus on the Government's internal processes, but the provisions most likely to affect contractors directly are the requirement for appointment of a qualified contracting officer's representative (COR) or contracting officer's technical representative (COTR) prior to award of cost-reimbursement contracts and assignment on a non-delegable basis to the cognizant federal agency official (CFAO -- generally the ACO for DOD contractors) of responsibility for determining the adequacy of the contractor's accounting system during the entire period of contract performance, with no express limit in the regulation as to the type of contract covered by that provision.

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Client Alert | 4 min read | 08.14.26

License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations

On August 12, 2026, the White House released a National Security Presidential Memorandum (NSPM) making a seismic shift in U.S. cybersecurity policy and establishing a framework to authorize private-sector companies to conduct offensive cyber operations — historically strictly prohibited by federal law — against foreign Cyber-Enabled Transnational Criminal Organizations (CE-TCO). It builds on an executive order issued in March 2026 that directed federal agencies to develop plans to combat cybercrimes against Americans....