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Not So Fast – GSA Implements New SAM Registration Requirements After Fraudulent Activity

Client Alert | less than 1 min read | 04.17.18

Following fraudulent activity in the System for Award Management (SAM), the General Services Administration (GSA) is implementing new requirements for registration in SAM.  Effective March 22, 2018, new entities to SAM are now required to submit a notarized letter identifying their authorized Entity Administrator before a new SAM registration is activated, and beginning April 27, 2018, entities with existing SAM registrations will also be required to submit this notarized letter to confirm the authorized Entity Administrator before current SAM registrations are updated or renewed.

To read more, visit our blog post on the topic.

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....