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Substantial Changes To CAS Administration Regulations

Client Alert | 1 min read | 03.16.05

Final rules, effective April 8, 2005, concerning proposed changes to CAS administration requirements that have been pending since April 2000 were promulgated on March 9, 2005 (70 Fed. Reg. 11743-61). The new regulations will be discussed in detail at the upcoming OOPS/WOOPS programs on March 31-April 1/April 14-15, but some of the highlights include:

  • When there is a CAS noncompliance, contract price adjustments may be required for closed contracts and closed years,
  • Improvement in the definition of "desirable" and "required" changes may permit contractors to avoid price adjustments,
  • Retroactive accounting changes are permitted in limited circumstances,
  • Widely criticized proposals to prohibit offsets between FFP and flexibly-priced contracts were abandoned, and
  • Estimates to complete rather than original cost estimates must be used to determine cost impact on FFP contracts.

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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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