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OMB Releases Final Federal Source Code Policy

Client Alert | 1 min read | 08.12.16

On August 8, 2016, OMB released the final federal source code policy, which requires new, custom-made source code developed specifically by or for the federal government to be made available for sharing and reuse across all federal agencies in an effort to minimize duplicative procurements and reduce federal vendor lock-in. The policy also establishes a pilot program that requires agencies commissioning new, custom software to release at least 20 percent of that code as open source software (OSS) for three years, which will require agencies to consider the value of publishing custom code as OSS and negotiate data rights reflective of its value, as well as to obtain sufficient rights to fulfill the policy’s objectives.


Insights

Client Alert | 3 min read | 08.18.25

FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment

On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines....