Offerors Now Must Disclose Information about Owners, Subsidiaries, and Predecessors
Client Alert | less than 1 min read | 03.09.16
On March 7, 2016, the FAR Council issued a final rule that requires offerors to disclose within the Federal Awardee Performance and Integrity Information System any immediate owner or subsidiary and all predecessors of an offeror that held a federal contract or grant within the last three years. The final rule is designed to provide COs with a “more comprehensive understanding of the performance and integrity of the corporation before awarding a Federal contract . . .,” and it may also affect how contractors draft their proposals to explain their corporate family trees.
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Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.
Client Alert | 3 min read | 07.15.26
Client Alert | 3 min read | 07.14.26
Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine
