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New Post-Employment "Revolving Door" Certification

Client Alert | 1 min read | 11.18.11

On November 18, 2011, in the wake of high-profile enforcement actions and bid protests demonstrating the risks involved when contractors recruit and hire former government personnel (e.g., Health Net Fed. Servs.), the DoD issued a final rule that, for the first time, will require offerors to certify that “all covered DoD officials employed by or otherwise receiving compensation from the offeror, and who are expected to undertake activities on behalf of the offeror for any resulting contract, are presently in compliance with all post-employment restrictions covered by 18 U.S.C. 207, 41 U.S.C. 2101-2107, and 5 CFR parts 2637 and 2641, including Federal Acquisition Regulation 3.104-2.”  This new requirement further reinforces the necessity for contractors to have robust internal systems to identify and monitor in a timely way the post-employment restrictions imposed on their employees and consultants who are former government personnel.

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Client Alert | 2 min read | 09.30.25

CARB Issues Preliminary List of Entities Covered by California Climate Disclosure Laws

On September 24, 2025, the California Air Resources Board (“CARB”) issued a preliminary list of reporting/covered entities under California’s climate disclosure laws SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act) (the “Climate Disclosure Laws”) (both as modified by SB 219)....