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Securing the Information and Communications Technology Services Supply Chain – Proposed Department of Commerce Rule

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| January 16, 2020

The Department of Commerce (Commerce) recently issued a proposed regulation to better secure the United States’ information and communications technology and services (ICTS) supply chain. The ICTS supply chain supports how government, industry and the public communicate and conduct their business. The ICTS supply chain encompasses the generation, storage and transmission of data for criticalRead More

Topics: Sourcing Restrictions

GAO Reminds Offerors that It’s Important to Substantiate Key Personnel’s Experience

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| January 16, 2020

Putting your best foot, or best personnel, forward seems like “Winning the Contract Award 101.” But a refresher course never hurts. Recently, the Government Accountability Office (GAO) decision in Deloitte Consulting, LLC (Deloitte), B-416882.4 (January 6, 2020), provided a reminder about the content of a quotation where the solicitation requires submission of a crosswalk, resume,Read More

Topics: Bid Protests and the Contracting Process

New Year, New Voluntary Self-Disclosure Policy for Export Controls and Sanctions

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| January 16, 2020

Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations, something is wrong. He reasoned that every company is made up of human beings—and human beings make mistakes, so every company doing lotsRead More

Topics: Export Controls, Sanctions and CFIUS, International, Battlefield and Contingency Contracting, Statutes and Regulations

New Changes to the ITAR Focus on Unclassified Technical Data And the release of “Access Information”

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| January 10, 2020

As part of its years-long project to update and revise the International Traffic in Arms Regulations (ITAR) and better align them with the Export Control Regulations, the Department of State (DoS) recently amended the ITAR with an interim rule to address another group of amendments first proposed in June of 2015. The new rule definesRead More

Topics: Cyber, Data Security, and Privacy, Export Controls, Sanctions and CFIUS, International, Battlefield and Contingency Contracting, Statutes and Regulations

Small Business Runway Act Regulation Goes Into Effect – You May Have a Choice in How to Calculate Your Size

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| January 10, 2020

Being a small business can have its advantages. Federal procurement rules provide that certain contracting opportunities may be set-aside for small business competition. Small businesses also may be exempt from certain procurement provisions, such as subcontracting plan requirements and coverage under Federal Cost Accounting Standards (CAS). Prime and higher-tier subcontractors also are incentivized to useRead More

Topics: Size Protest, Small Business / Socioeconomic Issues, Subcontracting and Strategic Alliances