New York State Debarment Risk Update
Client Alert | 1 min read | 04.05.19
Highlighting the renewed focus on debarment in state and local contracting, the state of New York recently reminded purchasing agencies of their obligations to debar non-responsible contractors and to confirm that intended awardees are otherwise eligible before awarding contracts. Executive Order (EO) 192, issued by Governor Cuomo, directs purchasing entities to consider vendor responsibility by evaluating, among other factors, financial and organizational capacity, integrity, and past performance. If buying agencies become concerned about a contractor’s responsibility, the EO instructs agencies to conduct an investigation and make a responsibility determination. Agencies are required to list nonresponsible vendors on the Office of General Services’ website. No state agency may purchase from a vendor on that list, absent a waiver, or agency leadership risks “breaching their duty as a public officer . . . ” suggesting that contract rescissions may follow, among other consequences.
Insights
Client Alert | 3 min read | 07.18.25
Eighth Circuit Cancels Click-to-Cancel
On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements.
Client Alert | 9 min read | 07.18.25
U.S. Lifts Most Sanctions on Syria in Major Policy Development
Client Alert | 6 min read | 07.17.25
Client Alert | 3 min read | 07.17.25
(Not the Funniest) Weekend Update: Recap of Recent Developments in the EU-US Tariff Dispute
