News & Analysis as of

Suspensions & Debarments

McDermott Will & Emery

The New UK Procurement Regime and the Economic Crime & Corporate Transparency Act: Heightened Exclusion & Debarment Risks

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The UK Procurement Act 2023 (the Procurement Act) came into force on 24 February 2025. It introduced significant changes to the UK public procurement landscape including a new regime for suppliers to be excluded from a...more

Dickinson Wright

The Air Force “Contractor Responsibility Watch List” De Facto Debarment for Space Companies?

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The Air Force is showing increased interest in using its Contractor Responsibility Watch List (CRWL). This is for companies that, in the agency’s view, should be blocked from further space projects. ...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – March 2025 #2

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March 2025: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors - On top of the uncertainty introduced through the Trump administration’s shifting priorities and rapid-fire executive orders,...more

PilieroMazza PLLC

Guilty Until Proven Innocent: Key Takeaways from the Recent Final Rule on the FAR’s Suspension and Debarment Procedures

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In a recent Final Rule (Rule) made effective January 17, 2025, the Federal Acquisition Regulation’s (FAR) suspension and debarment procedures were revised to be more consistent with the procedures in 2 CFR part 180 applicable...more

Pillsbury Winthrop Shaw Pittman LLP

Navigating Stop-Work and Suspension Orders Under Trump 2.0

Federal contractors and grant recipients facing stop-work or suspension orders are entitled to reimbursement of costs and added performance period. In its first two weeks, the new Trump administration has introduced a flurry...more

Goodell, DeVries, Leech & Dann, LLP

Judge’s Suspension is a Cautionary Tale

Last week, the Maryland Supreme Court suspended Maryland District Court Judge Jennifer Etheridge for 20 days for violations of the Maryland Code of Judicial Conduct. The charges, Etheridge’s response, and the order from the...more

Morrison & Foerster LLP - Government...

Pause Patrol: What to Do If the New Administration Yanks the Leash on Your Contracts or Grants

A flurry of presidential directives, agency communications, and court orders has left federal contract and grant recipients with operational disruptions and in a state of confusion. As we write, it has been difficult to...more

Hogan Lovells

FAR Council Finalizes Revisions to FAR Part 9’s Suspension and Debarment Regulations

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On January 3, 2025, the Department of Defense, General Services Administration, and National Aeronautics and Space Administration (collectively, the Federal Acquisition Regulation (FAR) Council) issued a final rule, Improving...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Government Contracting Compliance & Ethics Conference - February 27th, 8:00 am - 5:00 pm CT

Stay on top of the complexities of government contracting - Few industries are as heavily regulated or complex as government contracting. If your organization performs government-contracted services, or if you are charged...more

Cohen Seglias Pallas Greenhall & Furman PC

Changes to the Suspension and Debarment Rules in 2025

A contractor who is proposed for debarment is effectively debarred as soon as the notice letter is received. It is like being sentenced before trial and it can take weeks, or months, for the contractor to convince the...more

Blank Rome LLP

Three Major Features of the New Final Rule on Suspension and Debarment

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Introduction - On January 3, 2025, the Federal Acquisition Regulatory Council (“FAR Council”) published a long-awaited final rule to update suspension and debarment procedures. 90 Fed. Reg. 507. The final rule takes...more

Maynard Nexsen

FAR Council Publishes Final Rule to Update Suspension and Debarment Procedures

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On January 3, 2025, the Defense Department, GSA, and NASA (together, the "FAR Council") published its final rule amending the suspension and debarment procedures under the Federal Acquisition Regulation ("FAR"). The rule,...more

Morrison & Foerster LLP - Government...

Shoot First, Ask Questions Later: Final Rule Keeps FAR’s Inconsistent Treatment of Proposed Debarments

The Federal Acquisition Regulation (FAR) Council has issued a final rule, effective January 17, 2025, to improve the consistency between the procurement and nonprocurement procedures for suspension and debarment. The changes,...more

Wiley Rein LLP

FAR Council Issues Long-Awaited Final Rule to Harmonize (Almost) Procurement and Nonprocurement Suspension and Debarment Rules

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WHAT: On January 3, 2025, the Federal Acquisition Regulation (FAR) Council published its final rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more

Womble Bond Dickinson

Upcoming Changes in Defense Related Procurement: What You Need to Know

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When we talk about defense related procurement, we're referring to defense and security contracts which are public contracts. Defense procurement reform has been a significant topic on the House of Commons agenda for...more

Davies Ward Phillips & Vineberg LLP

Updated “Ineligibility and Suspension Policy”: Are You at Risk of Losing Your Right to Contract with the Canadian Government?

The new policy provides for increased flexibility in the assessment of a supplier’s conduct, but targets a much broader range of situations triggering ineligibility, Introduction - The Government of Canada recently updated...more

Clark Hill PLC

A Cautionary AI Tale for Federal Contractors

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Much has been and will be written on responsibility determinations and compliance programs in federal contracting, particularly at the intersection of cybersecurity and recent developments. Although a federal contract is not...more

Vinson & Elkins LLP

World Bank Group’s Watchful Eye: A Reminder of How Minor Ethical Breaches Can Result in Major Problems

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While much attention is given to compliance with applicable laws, such as the U.S. Foreign Corrupt Practices Act of 1977, many companies working on projects sponsored by Multi-Lateral Development Banks (“MDBs” or “MDB”)...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for March 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Holland & Knight LLP

Small Business Subcontracting Plans: Do Lessors Need Them, and What Do They Do?

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First-time landlords to the government are often overwhelmed by the number of Federal Acquisition Regulation (FAR) and General Services Acquisition Regulation (GSAR) clauses included in government leases. The compliance...more

Balch & Bingham LLP

7 Ways That Davis-Bacon Changes Could Cost Contractors

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Significant new changes to the Davis-Bacon Act and Related Acts will play a critical role as federal contractors consider and prepare for construction projects in 2024, affecting labor and administrative costs as well as how...more

Blank Rome LLP

My Company Just Got a Notice of Proposed Debarment. Now What?

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Receiving a Notice of Proposed Debarment from a federal agency Suspending and Debarring Official (“SDO”) is an alarming moment for any government contractor. It means the government believes there is a basis to question...more

Seyfarth Shaw LLP

FAR Council Proposes Revisions to Suspension and Debarment Rules

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Suspension and debarment are among the most powerful administrative remedies the Government has at its disposal to address non-compliance with laws and regulations, and to protect the Government’s business interests....more

Wiley Rein LLP

FAR Council Proposes Changes to Harmonize Procurement and Nonprocurement Suspension and Debarment Rules

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WHAT: On January 9, 2024, the Federal Acquisition Regulation (FAR) Council published a proposed rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more

Venable LLP

A New Rule Runs an End Around Suspension and Debarment Regulations and Will Require Contractors to Scour Their Supply Chains for...

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In recent years, we have seen statutory and regulatory exclusions from federal contracting of various entities and their goods and services happening outside the normal suspension and debarment process, the most notable being...more

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