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Getting to Know SAM

Client Alert | less than 1 min read | 08.02.12

On July 29, 2012, the government launched the System for Award Management, known as SAM, which consolidated the Central Contractor Registration (CCR), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS). CCR and ORCA are no longer accepting new or updated submissions, so contractors may be particularly interested in exploring the SAM User's Guide to learn how to submit information in this new system.

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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....