1. Home
  2. |Insights
  3. |FTA Softens Blow of Stricter Buy America Requirements for Rolling Stock

FTA Softens Blow of Stricter Buy America Requirements for Rolling Stock

Client Alert | 1 min read | 04.12.16

On April 6, 2016, the Federal Transit Administration proposed a policy statement and a public interest waiver, both clarifying that the increased U.S. content percentages mandated by the FAST Act will not apply to contracts entered into before the act’s October 1, 2015, effective date and waiving application of the higher percentages to any other contracts resulting from solicitations advertised prior to December 4, 2015 (the date the law was enacted). The FAST Act itself provided some relief from the increased percentages by requiring the FTA, when denying non-availability waivers, to certify to the identity of domestic suppliers of the iron, steel, or manufactured good at issue and by allowing inclusion of domestically sourced iron or steel used in foreign manufactured car shells or rolling stock frames to be included in the calculation of the domestic cost percentage.

Contacts

Insights

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....

View All Insights