News & Analysis as of

Interim Rule

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Will Not Enforce the CTA Until Interim Rule is Effective

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it will not issue any fines or penalties or initiate any other enforcement action against companies that do not file or update...more

Miles & Stockbridge P.C.

Interim Rule Clarifies Requirements for Registration in System for Award Management

Miles & Stockbridge P.C. on

The Federal Acquisition Regulatory (FAR) Council issued an interim rule earlier this month revising FAR 52.204-7 to require offerors to be registered in System for Award Management (SAM) at two points in time: “[1] when...more

Snell & Wilmer

Opening the Skies: U.S. Eases Export Controls to Propel Innovation and Global Collaboration

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In a significant move to bolster the space industry and strengthen international partnerships, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a series of modifications to export controls on...more

Schwabe, Williamson & Wyatt PC

SAM Registration Lapses No Longer Fatal to Contract Awards

As we have previously discussed, businesses that contract with the U.S. government must maintain System of Award Management registration to be eligible for contract awards. We have also discussed the requirement that SAM...more

Maynard Nexsen

FAR Council Issues Interim Rule Removing SAM.gov Registration Continuity Requirement

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On November 12, the Department of Defense, General Services Administration, and the National Aeronautics and Space Administration (together, the "FAR Council") issued an interim rule, effective November 12, 2024, to amend the...more

Wiley Rein LLP

FAR Council Issues Interim Rule Prohibiting Procurement and Operation of Certain Unmanned Aircraft Systems

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WHAT: On November 12, 2024, the Federal Acquisition Regulatory Council (FAR Council) issued an interim rule amending the FAR to implement the statutory prohibition on procurement and operation of unmanned aircraft systems...more

Torres Trade Law, PLLC

New BIS Rule Grants Australia and the UK “Nearly” the Same Treatment as Canada

Torres Trade Law, PLLC on

On April 19, 2024, the Department of Commerce Bureau of Industry and Security (“BIS”) published an interim final rule (“Interim Rule”), amending the Export Administration Regulations (“EAR”) to enhance cooperation and...more

Pillsbury Winthrop Shaw Pittman LLP

Interim Rule Establishes New Supply Chain Diligence Requirements for Contractors

A new interim rule aimed at safeguarding the federal supply chain prohibits contractors from delivering or using covered articles and sources subject to exclusion or removal orders issued under the Federal Acquisition Supply...more

Wiley Rein LLP

Interim Rule Requires Contractors to Secure Supply Chains Involving Covered Articles and Sources Subject to FASC Exclusion and...

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WHAT: A new interim rule prohibits contractors from delivering or using covered articles and sources that are subject to exclusion or removal orders issued under the Federal Acquisition Supply Chain Security Act of 2018...more

Sheppard Mullin Richter & Hampton LLP

Interim Rule Effective in December Establishes Requirements for Contractors to Remove Identified Products and Services from the...

On October 5, 2023, the FAR Council released an Interim Rule on “Implementation of Federal Acquisition Supply Chain Security Act (FASCSA) Orders.” The Interim Rule implements requirements from Section 202 of the Federal...more

Fisher Phillips

What Federal Contractors Need to Know about the TikTok Ban for Government Devices: Your 5-Step Compliance Plan

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Federal contractors beware: the recent rule banning the TikTok app from government devices applies to all government contracts — and includes personal devices used for federal contract work. The government issued an interim...more

Best Best & Krieger LLP

U.S. Department of Treasury Releases Updated ARPA Interim Final Rule

The Consolidated Appropriations Act of FY23 created new American Rescue Plan Act (ARPA) eligibility – to include response to natural disasters, to build critical information, and support community development. On August 10,...more

ArentFox Schiff

New Government Forced Labor Actions Reemphasize Supply Chain Diligence for Government Contractors and Importers

ArentFox Schiff on

Several recent US governmental regulatory actions intended to combat forced labor serve as a reminder to government contractors and importers of their need to conduct appropriate “know your supplier” due diligence to identify...more

Davis Wright Tremaine LLP

China's Cyberspace Administration Releases "Interim" Rules Regulating the Use of Generative AI

The Cybersecurity Administration of China ("CAC") and six other agencies jointly promulgated Interim Measures for the Administration of Generative Artificial Intelligence Services ("Generative AI Measures" or "Rules"), that...more

Proskauer - Government Contractor Compliance...

FAR Council Bans TikTok from Federal Contractor Devices  

On June 2, 2023, the Federal Acquisition Regulation (FAR) Council published an interim rule which requires contracting officers to insert a new clause – FAR 52.204-27 – in solicitations after June 2, 2023 or when exercising...more

Schwabe, Williamson & Wyatt PC

TikTok Ban on Contractor Devices

The Department of Defense, General Services Administration, and NASA have issued a new interim rule, FAR 52.204–27, implementing Section 102 of Division R of the Consolidated Appropriations Act, 2023 (Pub. L. 117–328), the...more

Holland & Knight LLP

Contractors: Direct Employees to Remove TikTok from Personal Cell Phones, Other Devices

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Holland & Knight previously noted an Office of Management and Budget (OMB) memorandum prohibiting the use of TikTok on information technology used by federal agencies and contractors. (See Holland & Knight's previous blog...more

Venable LLP

Congressional, Executive, and Legal Developments for Government Contractors to Consider - June 2023

Venable LLP on

Each month, Venable's Government Contracts Group publishes a summary of recent legal developments of interest to the government contractor community. President Signs Fiscal Responsibility Act Suspending Debt Ceiling: The...more

Venable LLP

New FAR Clause Implements TikTok Ban for Federal Contractors

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The federal government's most recent TikTok ban is both simple and complex. The prohibition bans federal contractors from using or even installing the TikTok app on covered information technology (IT) devices....more

WilmerHale

PTAB/USPTO Update - April 2023

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On March 6, the USPTO announced a new Green Energy Category of its Patents for Humanity Program. Patents for Humanity is an awards competition that recognizes innovators who use technology to meet global humanitarian...more

Eversheds Sutherland (US) LLP

DEA confirms Delta-8 THCO & Delta-9 THCO are schedule I controlled substances but confusion remains

The US Drug Enforcement Agency (DEA) recently stated that delta-8 THC acetate ester (delta-8 THCO) and delta-9 acetate ester (delta-9 THCO) are not hemp, but Schedule I controlled substances under the Controlled Substances...more

Esquire Deposition Solutions, LLC

Indiana High Court Is Latest to Examine “Good Cause” for Remote Proceedings

Increasingly, the phrase “good cause” is being used by courts to decide whether a deposition or other judicial proceeding should be conducted remotely or in person. Depending on the jurisdiction and the precise nature of the...more

Morgan Lewis

Defense Contractors Must Disclose China Work to US Government

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The Department of Defense issued an interim rule amending the Defense Federal Acquisition Regulation Supplement to require bidders on defense contracts to disclose when work will be performed in the People’s Republic of...more

Wiley Rein LLP

Department of Defense Issues Interim Rule Requiring Disclosure of Chinese Workforce and Facilities

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WHAT: The Department of Defense (DoD) issued an interim rule requiring certain Defense contractors and subcontractors to disclose the use of workers and facilities in People’s Republic of China (PRC)....more

Holland & Knight LLP

Highly Anticipated Third Interim Final Rule on Surprise Billing Released

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The U.S. Departments of Health and Human Services (HHS), Labor and the Treasury (the Departments) have issued a highly anticipated third interim final rule (IFR) implementing the No Surprises Act (NSA). The rule, issued on...more

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