OCI Mitigation Doesn't Go Far Enough
Client Alert | 1 min read | 02.13.06
In Greenleaf Constr. Co. (Jan. 17, 2006, http://www.gao.gov/decisions/bidpro/29310518.pdf), GAO found an unmitigated organizational conflict of interest because the owner of the awardee was to receive a stream of payments from another contractor that the awardee would be overseeing and evaluating and whose economic well-being the awardee therefore could significantly affect. The owner of the awardee had been required by the agency to sell the other contractor in order to avoid having an OCI interest in the profits of that other contractor, but GAO found that the interest of the awardee's owner in ensuring that the other contractor would be able to continue making the payments to him might impair the awardee's objectivity in performing its contract evaluation duties.
Insights
Client Alert | 4 min read | 02.20.26
SCOTUS Holds IEEPA Tariffs Unlawful
On February 20, 2026, the Supreme Court issued a pivotal ruling in Trump v. V.O.S. Selections, negating the President’s ability to impose tariffs under IEEPA. The case stemmed from President Trump’s invocation of IEEPA to levy tariffs on imports from Canada, Mexico, China, and other countries, citing national emergencies. Challengers argued—and the Court agreed—that IEEPA does not delegate tariff authority to the President. The power to tariff is vested in Congress by the Constitution and cannot be delegated to the President absent express authority from Congress.
Client Alert | 7 min read | 02.20.26
Section 5949 Proposed Rule Puts the FAR Council's Chips on the Table
Client Alert | 5 min read | 02.20.26
Trump Administration Pursues MFN Pricing for Prescription Drugs
Client Alert | 4 min read | 02.19.26
Proposed NY Legislation May Mean Potential Criminal Charges for Unlicensed Crypto Firms
