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Setting the Floor: New FAR Rule Defines Minimum Contractor Information System Safeguarding

Client Alert | 1 min read | 05.17.16

Shifting approaches, on May 16, 2016, the FAR Council concluded a long-running rulemaking with a final rule and a new clause, FAR 52.204-21, that will establish minimum security controls pulled from NIST Special Publication 800-171 over contractor information systems that may process, store, or transmit “Federal contract information,” defined as information provided to or generated under any government contract (except for COTS) that is not intended for public release. Future rules will address more specific controls applicable to more sensitive information such as Controlled Unclassified Information (CUI), but this rule focuses instead on establishing those baseline controls the FAR Council believes any prudent business would implement in relation to its information systems and does not replace more stringent security requirements like those in the DFARS Safeguarding Rule.

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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....

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