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National Defense Authorization Act Reporting Requirements Federal Contractors

The National Defense Authorization Act is a United States federal statute enacted each year to specify the budget and expenditures of the Department of Defense. The NDAA identifies which agencies are responsible... more +
The National Defense Authorization Act is a United States federal statute enacted each year to specify the budget and expenditures of the Department of Defense. The NDAA identifies which agencies are responsible for national defense, provides funding for those agencies and includes instructions on proper use of the funds.  less -
Seyfarth Shaw LLP

The New Administrative False Claims Act: Key Amendments and Implications

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On December 23, 2024, the Servicemember Quality of Life Improvement and National Defense Authorization Act (NDAA) for Fiscal Year 2025 (FY 2025 NDAA) (P.L. 118-159) was signed into law. Among its numerous provisions, the FY...more

Kilpatrick

Recent Changes in Appropriations Legislation May Have Given "Baby False Claims Act" New Teeth

Kilpatrick on

On December 23, 2024, President Biden signed into law H.R. 5009 - “Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025.” (2025 NDAA). First passed in 1961, the NDAA is a...more

MoFo Employment Law Commentary (ELC)

FAR Council Withdraws “Pay Equity and Transparency” Proposed Rule

On January 8, 2025, the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulation (FAR) Council withdrew a proposed rule that would have banned federal contractors and subcontractors from seeking or...more

Goodwin

Focus on FOCI: Expanded Reporting Requirements Arrive for Defense Contractors

Goodwin on

On May 13, 2024 the U.S. Department of Defense (DoD) published Instruction 5205.87: Mitigating Risks Related to Foreign Ownership, Control, or Influence for Covered DoD Contractors and Subcontractors (the Instruction), which...more

BakerHostetler

Navigating Cyber and Legal Challenges During the M&A Process: Quick Considerations for Federal Contractors

BakerHostetler on

Merger and acquisition (M&A) activity is often the lifeblood of corporate growth. While whole treatises can be, and have been, written on cybersecurity and legal challenges during M&A activity, the following are a few key...more

Wiley Rein LLP

DOD Launches Pilot Program for Sole Source Follow-on Awards to ESOPs

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On October 10, 2024, the U.S. Department of Defense (DOD) issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a pilot program allowing for sole source follow-on contract...more

Wiley Rein LLP

New DOD Rules on Contractor Reporting and Mitigating Foreign Ownership, Control or Influence for Unclassified Contracts

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As a result of a broader U.S. government effort to address supply chain vulnerabilities, Congress passed a new law focused on U.S. Department of Defense (DOD) contracting with certain entities that operate under foreign...more

Jenner & Block

Changes to Reporting Requirements for U.S. Defense Transactions

Jenner & Block on

The National Defense Authorization Act was revised in December to state that parties to an HSR-reportable transaction that “will require a review by the Department of Defense who are required to file the notification and...more

Sheppard Mullin Richter & Hampton LLP

Updates on GHG Emissions Disclosure Requirements

Class Deviation Prohibits DoD from Requiring Contractors to Disclose Emissions - Over the past two years, the FAR Council has been working to develop a rule that would amend the Federal Acquisition Regulation (“FAR”) to...more

Pillsbury Winthrop Shaw Pittman LLP

DoD Requires Data Reporting for Certain Service Contracts Exceeding $3 Million

The Department of Defense (DoD) issued a final rule on July 9, 2021, requiring contractors to report annually their total labor hours and invoiced amounts for certain service contracts. Requirement applies to contracts...more

Nutter McClennen & Fish LLP

The Corporate Transparency Act: FinCEN to Collect Beneficial Ownership Information

The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more

Sheppard Mullin Richter & Hampton LLP

The NISPOM is Becoming a Regulation & Contractors Have Six Months to Comply

On December 21, 2020, the Department of Defense (“DoD”) published a final rule in the Federal Register that codifies the National Industrial Security Program Operating Manual (“NISPOM”) in the Code of Federal Regulations...more

Miller Canfield

New Corporate Transparency Act Will Impose Beneficial Ownership Reporting Requirements on Many Companies, Particularly Small...

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The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more

Winstead PC

A Brave New World: U.S. Implements Company UBO Reporting Regime

Winstead PC on

Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more

Holland & Knight LLP

DoD Codifies NISPOM, Formalizes Certain Personnel Reporting Requirements and Eases FOCI Burden

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In a final rule effective Feb. 24, 2021, the U.S. Department of Defense (DoD) codified the National Industrial Security Program Operating Manual (NISPOM) in Title 32, Part 117 of the Code of Federal Regulations. Of primary...more

Sheppard Mullin Richter & Hampton LLP

GSA’s Take on Implementation of Section 889 | Government Contracts & Investigations Blog

On September 10, 2020, the General Services Administration (“GSA”) hosted a webinar related to its implementation of Section 889 of the 2019 NDAA – the ban relating to certain Chinese telecom companies – and associated...more

Akin Gump Strauss Hauer & Feld LLP

Section 889(a)(1)(B): Five Things to Know About the Interim Rule and a Roadmap for Compliance

- Akin Gump is hosting a Webinar tomorrow, August 6, 2020, at 12:00 p.m. (EST) to discuss Section 889, the implementing regulations, and the grant and loan restrictions also effective August 13, 2020. - On July 14, 2020,...more

Seyfarth Shaw LLP

New Federal Contract Reporting Requirements Aimed at Protecting Supply Chains Through Detection of Counterfeit Parts

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Federal contractors already subject to a myriad of reporting requirements should be prepared for yet another. Effective December 23, 2019, a new Federal Acquisition Regulation (“FAR”) provision entitled “Reporting of...more

Sheppard Mullin Richter & Hampton LLP

Effective Immediately! – FAR Amended to Include Prohibition on Chinese Telecommunications Equipment and Services in Government...

In accordance with Section 889(a)(1)(A) of the 2019 National Defense Authorization Act (Pub. L. No. 115-232) (the “2019 NDAA”), which required imposition of broad restrictions on procurements involving certain Chinese...more

Akin Gump Strauss Hauer & Feld LLP

Agencies Release Interim Final Rule Implementing First Phase of 2019 NDAA Section 889

• On August 7, the DOD, GSA, and NASA released a prepublication version of an Interim Final Rule implementing paragraph (a)(1)(A) of § 889 of the 2019 NDAA. The rule is effective next Tuesday, August 13, 2019. • Among its...more

Pillsbury Winthrop Shaw Pittman LLP

Congressional Blue-Ribbon Panel Recommends Major Changes to DoD Acquisition Process

The Section 809 Panel has issued its final report with additional recommendations to streamline the DoD acquisition process, some of which would make revolutionary changes. The Section 809 Panel is a Congressionally...more

PilieroMazza PLLC

Weekly Update Newsletter - September 2016 #4

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GOVERNMENT CONTRACTS - Amendments to Department of Defense (“DOD”) Mentor-Protégé Program DOD has issued a proposed rule which will amend the DFARS to implement Section 861 of the NDAA 2016, which provides amendments...more

Davis Wright Tremaine LLP

More Cybersecurity Rules

This update will cover two things: (1) the new (yes, again) Department of Defense cybersecurity interim/final rule on reporting cyber incidents by contractors / subcontractors and (2) the money to fund these new rules and...more

Robinson+Cole Data Privacy + Security Insider

Interim rule requires Department of Defense contractors to report cyber breaches

Companies doing business with the U.S. Department of Defense are facing new requirements for reporting data security breaches and for acquiring cloud computing services. The Interim Rule, effective August 26, 2015, amends the...more

Davis Wright Tremaine LLP

DoD New Cyber Security Reporting Rules for Contractors

In a move that highlights the changing winds of federal cybersecurity policy, the Department of Defense (“DoD”) has issued an interim Rule (“Rule”) that imposes new security and reporting requirements on federal contractors,...more

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