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SBA Proposes Fundamental Revision to Subcontract Reporting

Client Alert | less than 1 min read | 10.08.15

On October 6, 2015, the SBA issued a proposed rule to change the way prime contractors report how they complied with individual subcontracting plan goals by allowing primes to receive credit for awards made at any subcontracting tier (instead of first-tier only). As part of this proposed change, primes would have to incorporate the subcontracting plan goals of their lower-tier subcontractors into their individual subcontracting plans and would become responsible for ensuring that subcontractors adopt and comply with their plans.


Insights

Client Alert | 10 min read | 03.16.26

Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold....