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Federal Government Invites Comment on Domestically Nonavailable Articles

Client Alert | less than 1 min read | 05.14.20

On May 13, 2020, the Federal Acquisition Regulatory (FAR) Council published an advance notice of proposed rulemaking inviting interested parties to submit information relevant to the periodic review of the FAR 25.104 list of domestically nonavailable articles exempt from the Buy American Act, either as end products or components. Companies have until July 13, 2020 to review their existing supply chains and identify articles or components that are not mined, produced, or manufactured in the United States in sufficient and reasonably available commercial quantities and of a satisfactory quality for addition to the list.

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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....