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Say Goodbye To CCR and Hello To SAM

Client Alert | 1 min read | 05.21.12

According to a post on Central Contractor Registration's website, "On May 29, 2012, the Central Contractor Registration (CCR) system is going away. CCR, along with Federal Agency Registration (FedReg), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS), will be migrated into the new System for Award Management, or SAM." While some details about this transition to SAM are currently available, the government is planning on providing additional information and training materials soon, and contractors should follow these developments closely because the government is reporting that CCR will stop accepting data at 11:59 pm on Wednesday, May 23, 2012, and no new registrations or updates can be submitted via CCR after that time.


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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

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