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Risk Of Accepting Out-Of-Scope Task/Delivery Orders Gets Greater

Client Alert | less than 1 min read | 10.07.04

Adding to the risk of accepting out-of-scope work that potentially could result in avoidance of the contract order, the GSA debarring official has recently put the burden on the contractor to police the situation: "We cannot have a situation where a contractor knows or should have known that something is wrong and does not at least raise the issue with the contracting officer, or, if appropriate, higher authority. On a case-by-case basis, if we determine that a contractor has not followed the rules, we may take appropriate action in the context of contractor responsibility."

Insights

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....