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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 | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....