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 | 7 min read | 12.17.25
After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations.
Client Alert | 1 min read | 12.17.25
Client Alert | 7 min read | 12.17.25
Executive Order Tries to Thwart “Onerous” AI State Regulation, Calls for National Framework
Client Alert | 4 min read | 12.17.25
The new EU Bioeconomy Strategy: a regulatory framework in transition
