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FAR Council Finalizes Reporting Requirements for Executive Compensation and First-Tier Subcontract Awards

Client Alert | less than 1 min read | 07.26.12

On July 26, 2012, the FAR Council issued a final rule requiring certain contractors to report executive compensation, first-tier subcontract awards, and executive compensation information for first-tier subcontractors for public release on the USASpending website. While the final rule is very similar to the interim rule issued on July 8, 2010, there is a substantive change to the definition of first-tier subcontract, and the preamble to the final rule contains extensive commentary to guide the implementation of the rule, including discussion of the application of the public company exemption.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....