1. Home
  2. |Insights
  3. |Sequestration Found Valid Basis for Canceling Solicitation

Sequestration Found Valid Basis for Canceling Solicitation

Client Alert | less than 1 min read | 09.23.13

In Vinculum Solutions, Inc. (Aug. 5, 2013), GAO, relying on the "broad discretion" afforded to agencies to define their needs and manage their procurements, concluded that the IRS's need to reduce costs due to the ongoing budget sequestration was a valid basis for canceling a solicitation. This appears to be the first decision in which GAO has considered the impacts of sequestration on the procurement process, and it may green-light similar actions in the months ahead for agencies coping with the ongoing sequester and the uncertainties of the FY14 appropriations process.


Insights

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....