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Expanding FAPIIS: First "Ownership," Now "Predecessors"

Client Alert | less than 1 min read | 12.17.14

On December 4, 2014, the FAR Councils issued a proposed rule that would require offerors to disclose all "predecessor" entities that held a federal contract or grant within the prior three years, with comments due by February 2, 2015. This information, in addition to the recent addition of ownership information, will be stored in the Federal Awardee Performance and Integrity Information System (FAPIIS).


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....