New Certification of Iran Sanctions Compliance - for You and Your Subsidiaries
Client Alert | 1 min read | 10.06.10
On September 29, 2010, the FAR Council published an Interim Rule with request for comment implementing the requirement in the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA") that every contractor certify that neither it, nor any entity owned or controlled by the contractor, engages in any activity for which sanctions could be imposed under section 5 of CISADA, including, for example, sales of goods, services, or technology that could directly and significantly facilitate the maintenance or expansion of Iran's domestic production of refined petroleum products. While the CISADA sanctions extend to both U.S. and foreign persons -- and the FAR Council has extended the certification requirement as broadly as possible to include procurements of commercial items, COTS items, and those below the simplified acquisition threshold -- to avoid any conflict with the U.S.'s commitments under the WTO Agreement on Government Procurement and other free trade agreements, contractors furnishing only "designated country" end products under a contract subject to the Trade Agreements Act are exempted from the certification requirement.
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Client Alert | 3 min read | 11.21.25
On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
Client Alert | 3 min read | 11.20.25
Client Alert | 3 min read | 11.20.25
Client Alert | 6 min read | 11.19.25
