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Proposed Federal Guidelines For Compliance Programs Published For Comment

Client Alert | less than 1 min read | 01.07.04

By our earlier Bullet Point (Oct. 7, 2003), we advised that the US Sentencing Commission was considering substantial revisions to its guidelines for organizations and courts on what constitutes an effective compliance program. The proposed guidelines were published on 12/30/03 (68 FR 75340) for public comment, closing on 03/01/04.

Insights

Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....