Proposed NRO Clause Would Require Broad Disclosure -- Comments Due Tomorrow
Client Alert | 1 min read | 02.12.04
The proposal of the National Reconnaissance Office (NRO) to add a new standard clause to its contracts that would provide that "contractors and their employees, agents, representatives, subcontractors, and employees of subcontractors shall report to the NRO Inspector General (IG) or General Counsel any and all possible violations of federal criminal law or illegal intelligence activities of which they become aware during performance under an NRO contract," make all relevant records and employees available to the IG (failure to do so grounds for default termination), and flow the clause down to subcontractors raises obvious and serious policy issues. The request for comments are due tomorrow, February 13, despite only being published on February 4, on the NRO website, where the full text of the proposed clause is available.
Insights
Client Alert | 8 min read | 09.09.25
On September 5, 2025, the Federal Trade Commission (“FTC”) withdrew its appeals of decisions issued by Texas and Florida federal district courts, which enjoined the FTC from enforcing a nationwide rule banning almost all noncompete employment agreements. Companies, however, should not read this decision to mean that their noncompete agreements will no longer be subjected to antitrust scrutiny by federal enforcers. In a statement joined by Commissioner Melissa Holyoak, Chairman Andrew Ferguson stressed that the FTC “will continue to enforce the antitrust laws aggressively against noncompete agreements” and warned that “firms in industries plagued by thickets of noncompete agreements will receive [in the coming days] warning letters from me, urging them to consider abandoning those agreements as the Commission prepares investigations and enforcement actions.”
Client Alert | 12 min read | 09.09.25
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California’s Climate Disclosure Laws Continue to Roll Forward
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RADV Audits: Implications and Recommendations for Medicare Advantage Organizations
