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Weeding Out Bad Contractors -- The Government's Push to Enhance its Suspension and Debarment Function

Client Alert | 1 min read | 11.17.11

On November 15, 2011, the head of OMB, Jacob Lew, issued a memorandum requiring the heads of executive departments and agencies to increase management attention on suspension and debarment, consistent with the policies and procedures in the FAR. On the heels of the OMB memorandum, the U.S. Senate's Committee on Homeland Security and Governmental Affairs convened hearings on November 16 on "Weeding Out Bad Contractors," which featured testimony from, among others, Daniel Gordon, the Administrator for Federal Procurement Policy; David Sims, the Chair of the ISDC; and Steven Shaw, the Air Force’s debarment and suspension official.

For further analysis and links to the OMB Memo and Congressional testimony, click here for a related blog post by Daniel Forman.

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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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