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New Grant Rules Put Recipients Under the Microscope

Client Alert | 1 min read | 01.15.14

On December 26, OMB published new guidance designed to "streamline" the Federal government's guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal grants, an effort led by the cross-agency Council on Financial Assistance Reform and OMB. The new guidance is intended in part to "strengthen oversight over Federal funds to reduce risks of waste, fraud, and abuse" and "increase the efficiency and effectiveness of Federal awards to ensure best use of the more than $500 billion expended annually," an effort which is likely to mean increased government scrutiny over institutions of higher education, nonprofit organizations, and other grant recipients.


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....