Shades of Lazarus: Is Blacklisting Rule Coming Back to Life?
Client Alert | 1 min read | 07.17.17
On June 26, 2017, Senator Elizabeth Warren (D-MA) introduced a new bill titled the Contractor Accountability and Workplace Safety Act of 2017 (S. 1440) aimed at holding Department of Defense (DoD) contractors and covered subcontractors accountable for workplace safety and health violations of federal and equivalent state labor laws. Three days later, during a closed mark-up of the National Defense Authorization Act (NDAA) for Fiscal Year 2018 in the Senate Armed Services Committee (SASC), Senator Warren introduced – and the SASC accepted – an amendment to the NDAA at Sections 830 and 831, similar to S. 1440. Under both S. 1440, and Sections 830-831 in the Senate’s version of the NDAA, which echo the Obama-era “Fair Pay and Safe Workplaces” EO and implementing regulations, DoD contracting officers would be required to consider workplace safety and health violations when evaluating the responsibility of a prospective DoD contractor prior to awarding or renewing a contract valued in excess of $1,000,000, and, as appropriate, refer matters related to these violations to the DoD Suspension and Debarment Official, ostensibly to ensure contractors’ compliance with these existing laws and establish a goal for DoD to work with responsible, compliant contractors.
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Client Alert | 7 min read | 06.24.26
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.
Client Alert | 3 min read | 06.24.26
Client Alert | 4 min read | 06.23.26
EPA Hands Over AI Data Center Regulation to States and Communities to Develop Best Practices
Client Alert | 3 min read | 06.22.26



