Compliance

OSHA Suspends Enforcement of COVID-19 Vaccination-or-Test Requirement

OSHA Suspends Enforcement of COVID-19 Vaccination-or-Test Requirement On Thursday, November 4, 2021, the Department of Labor’s (DOL) Occupational Safety and Health Administration (OSHA) released its COVID-19 Vaccination and Testing Emergency Temporary Standard(ETS), which requires employers with more than 100 employees to mandate their workers are fully vaccinated or test at least weekly for COVID-19....
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Heads up, federal contractors: DoD has announced “CMMC 2.0” with significant changes to program structure and requirements, including expanded self-attestation that heightens False Claims Act exposure.

DOD REVAMPS CYBERSECURITY MATURITY MODEL CERTIFICATION (“CMMC”) ROBUST ENFORCEMENT LIKELY USING THE FALSE CLAIMS ACT CMMC Program Overview The CMMC program enhances cyber protection standards for companies in the Defense Industrial Base. It is designed to protect sensitive unclassified information that is shared by the Department of Defense (“DoD”) with its contractors and subcontractors....
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Office of Foreign Assets Control (“OFAC”) Sanctions Compliance Guidance for the Virtual Currency Industry

In mid-October 2021, OFAC issued sanctions compliance guidance (the “OFAC Guidance”) for the virtual currency industry, including tech companies, exchanges, administrators, miners, crypto wallet providers, and even users. OFAC issued the guidance to help the virtual currency industry mitigate the risks of transacting cryptocurrencies with a sanctioned country, entity, or individual. OFAC is the...
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FAR Council, CAAC, and DoD Release COVID-19 Guidance

The FAR Council, the Department of Defense (“DoD”), and the Civilian Agency Acquisition Council (“CAAC”) have released guidance for federal government contractors on COVID-19 safeguards required by President Biden’s September 9, 2021, Executive Order 14042 (the “Order”) and the Safer Federal Workforce Task Force’s September 24, 2021, Guidance, COVID-19 Workplace Safety: Guidance for Federal...
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Civilian Agency Acquisition Council (“CAAC”) Memorandum: Class Deviation Regarding Executive Order 14042 Ensuring Adequate COVID Safety Protocols for Federal Contractors

On September 30, 2021, the Civilian Agency Acquisition Council (“CAAC”) released a memorandum authorizing all civilian United States government agencies to issue a class deviation to implement Executive Order 14042, “Ensuring Adequate COVID Safety Protocols for Federal Contractors.” Attached to the CAAC memo is a FAR Deviation Clause (the “Clause”) that CAAC states “is...
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Federal Vaccine Mandate Requires Contractor Employees To Be Fully Vaccinated By December 8, 2021

Posted on September 27, 2021
Federal contractor employees—with some limited exceptions—must be vaccinated by December 8, 2021 per guidance released by the Biden administration on Friday.1 The mandate applies to part- and full-time employees of contractors (or subcontractors) who are working either directly on or “in connection with” a contract, including indirect support of a contract like “human resources, billing,...
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