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It’s Time for a Raise! DoD Proposes to Increase CPSR Threshold

Client Alert | 1 min read | 06.11.19

On May 31, 2019, DoD issued a proposed rule, which would amend the Defense Acquisition Regulation Supplement (DFARS) to establish a DoD-specific Contractor Purchasing System Review (CPSR) threshold of $50M at DFARS 244.302, to be used in lieu of $25M threshold at FAR 44.302(a), which has remained unchanged since 1996. According to the Federal Register, it is estimated that, with this new threshold in place, DCMA ACOs can reduce the number of contractor reviews by approximately 20% (from around 667 to 534), which would reduce the burden on smaller contractors and allow a more efficient and effective use of CPSR resources to review larger contractors where more taxpayer dollars are at risk. Comments on the rule are due by July 30, 2019.

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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....