GSA Quietly Raises the Cybersecurity Bar for Contractors Handling CUI
On January 5, 2026, the General Services Administration (“GSA”) issued CIO-IT Security-21-112 Revision 1, a procedural guide establishing new requirements for protecting Controlled Unclassified Information (“CUI”) in nonfederal contractor systems. While not promulgated as a FAR rule, the guide establishes a mandatory approval framework that contracting officers may apply immediately to new contracts involving...
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EEOC Rescinds Harassment Guidance, Creating New Uncertainty and Risks for Employers
On January 22, 2026, the U.S. Equal Employment Opportunity Commission (EEOC) voted 2–1 to rescind its 2024 Enforcement Guidance on Harassment in the Workplace. The decision revokes a comprehensive, 190‑page document that consolidated decades of case law and provided employers with detailed direction on identifying, preventing, and responding to unlawful harassment. The rescinded guidance...
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Use AI to support your work—not to replace your professional judgment
As Artificial Intelligence tools (such as ChatGPT, Harvey, CoPilot, Claude, etc.) become more accessible, many attorneys have begun exploring how to best use AI tools in their practices. While such tools can streamline workflows, there are many recent examples showing that AI is not a substitute for professional judgment and its misuse carries real...
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Understanding the New Executive Order Targeting “Underperforming” Defense Contractors
In an Executive Order issued on January 7, 2026, entitled “Prioritizing the Warfighter in Defense Contracting,” President Trump announced a new effort to identify suppliers of critical weapons and equipment that are underperforming on their contracts and, simultaneously, engaged in stock buy-backs or corporate distributions. According to the President, this new effort will focus...
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Corruption, Contracts, and Terrorism Financing: The D.C. Circuit Clarifies ATA Risk
Recent litigation in the D.C. Circuit highlights the growing legal risks facing companies operating in conflict-affected and high-corruption environments, particularly where commercial activity intersects with terrorist financing concerns. In Atchley v. AstraZeneca UK Ltd., the court revived claims under the Anti-Terrorism Act (“ATA”) alleging that pharmaceutical and medical equipment companies indirectly financed terrorist attacks...
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Protests Based on Impaired Objectivity Organizational Conflict of Interests (“OCI”) Continue to Find Success at GAO
In Solutions71, LLC: B-423671.2, GAO sustained the third impaired objectivity OCI protest within the last six months. GAO’s decision in Solutions71 joins Castro & Company, LLC: B- 423689 and DirectViz Solutions, LLC:B- 423366; B-423366.3; B-423366.4 in what has become an increasingly successful protest ground. What is an Impaired Objectivity OCI? An impaired objectivity OCI...
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