Relaxation Of Requirements = Out-Of-Scope Mod
Client Alert | less than 1 min read | 06.22.05
In Poly-Pacific Technologies, Inc. (June 1, 2005 http://www.gao.gov/decisions/bidpro/296029.pdf), GAO found that an agency's modification that relaxed the requirements of an existing contract amounted to an improper out-of-scope modification and that the agency was required to have conducted a new competition. This decision shows that "cardinal" modifications can occur with relaxations, as well as expansions, of requirements.
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Client Alert | 5 min read | 02.23.26
UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations
The UK’s Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence concerning the "ownership and control" test within UK financial sanctions. The call for evidence, running until 11:59 p.m. on 13 April 2026, seeks stakeholder views on the challenges and implementation of the "control" limb, with particular focus on its hypothetical element.
Client Alert | 4 min read | 02.20.26
Client Alert | 7 min read | 02.20.26
Section 5949 Proposed Rule Puts the FAR Council's Chips on the Table
Client Alert | 5 min read | 02.20.26
Trump Administration Pursues MFN Pricing for Prescription Drugs

