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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SBA Issues Suspension Notices to 8(a) Participants That Failed to Timely Respond to Data Call With Complete Responses: What 8(a) Participants Need to Know
SBA Acts Quickly and Issues Suspension Notices On January 21, 2026, just two days after the deadline for all 8(a) Participants to respond to a comprehensive audit (often referred to as the “8(a) Data Call”), the SBA issued Notices of Suspension to 8(a) firms for apparent failure to submit all required documentation in response...
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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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GAO Sustains Protest Over CIA’s Faulty Cost Realism Evaluation
In a recent bid protest decision, Markon LLC, B-423767-.4, December 12, 2025, the Government Accountability Officer (GAO) delivered a pointed reminder about the limits of agency discretion in cost realism evaluations. In this case, which involved a solicitation for business operations, information technology engineering support, and business enterprise modernization services, the Central Intelligence Agency...
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What Federal Contractors Should Know About the Government Shutdown
Those of us who have spent time working in—or with—the federal government over the past several decades know that government shutdowns are not entirely uncommon. There have actually been a total of 21 government shutdowns over the past 50 years, with the last occurring in 2019 and the longest lasting 35 days. By the...
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Two CAS Moves in One Day: What Small Contractors Need to Know
On September 11, 2025, the Office of Management & Budget’s (“OMB”) Cost Accounting Standards Board, which is chaired by the Office of Federal Procurement Policy (“OFPP”), dropped two important updates: A final rule that simplifies how revenue and leases are handled under CAS; and A proposed rule that would scale back or align four...
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