On March 20, 2025, the White House issued Executive Order (“EO”), “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement,” to consolidate domestic civilian contracting for “common goods and services” within one agency—the General Services Administration (“GSA”). The EO defines “common goods and services” as those described in the Category Management system first developed as part of a previous effort, dating back to 2014, to coordinate spending across the government.Continue Reading Trump’s Government Contracts Rebrand: From “Government” Procurement to “Just-GSA” Procurements
SBA Issues “Day One” Memo – with a Particular Emphasis on Rooting out Fraud
On February 24, 2025, the Small Business Administration (SBA) issued a “Day One” memo outlining SBA Administrator Kelly Loeffler’s priorities.
The “Day One” memo highlights SBA’s focus on the Trump administration initiatives—including implementing President Trump’s executive orders; mandating that all non-exempt employees return to full-time, in-office work; and working closely with the Department of Government Efficiency (DOGE) in accomplishing accountability, transparency, and efficiency. SBA will relocate regional offices “currently based in sanctuary cities” to what it characterizes as “less costly, more accessible locations in communities that comply with federal immigration law.”Continue Reading SBA Issues “Day One” Memo – with a Particular Emphasis on Rooting out Fraud
District Court Grants Temporary Reprieve to USAID Implementing Partners
On February 13, 2025, Judge Amir Ali of the U.S. District Court for the District of Columbia issued a temporary restraining order in two combined cases—one filed by U.S. Agency for International Development (USAID) contractors, a second by USAID grant recipients—challenging Executive Order 14169, “Reevaluating and Realigning United States Foreign Aid,” which paused almost all foreign assistance funding. Continue Reading District Court Grants Temporary Reprieve to USAID Implementing Partners
New Year, Updated List: The U.S. Department of Defense Updates Its List of Chinese Military Companies with Ancillary Supply Chain and USG Contracting Impacts
On January 2, 2025, the U.S. Department of Defense (DoD) updated the 1260H List of entities identified as “Chinese military companies” (CMC) operating in the United States, as required by section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2021 (Section 1260H), adding new entities and removing others. The updated 1260H List now includes 76 entities. Continue Reading New Year, Updated List: The U.S. Department of Defense Updates Its List of Chinese Military Companies with Ancillary Supply Chain and USG Contracting Impacts
Special Edition of the Fastest 5 Minutes
New Administration – Domestic Preferences and Supply Chain Security
This week’s special edition focuses on what contractors can expect from the incoming administration relating to domestic preferences, supply chain security and sourcing, and evolving requirements and enforcement, and is hosted by Yuan Zhou, Addie Cliffe, and Alex Barbee-Garrett. Crowell & Moring’s “Fastest 5 Minutes” is
Six Years in the Making, DoD Releases Proposed Rule Requiring Disclosure of Foreign Review of Code for IT, Cybersecurity, Critical Infrastructure, and Weapons System Products and Services
On November 15, 2024, the Department of Defense (DoD) issued a Proposed Rule implementing Section 1655 of the John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2019 (P.L. 115-232), over six years after Congress enacted the requirement. Continue Reading Six Years in the Making, DoD Releases Proposed Rule Requiring Disclosure of Foreign Review of Code for IT, Cybersecurity, Critical Infrastructure, and Weapons System Products and Services
SAM Scams: Protect Your Company
Recently, there has been a significant increase in scams targeting users of the System for Award Management (SAM.gov). Active SAM registrations are required for federal government contractors, including to receive contracts and payments. The non-public portions of these registrations include bank account information, tax information, and other sensitive information about a company. Recent phishing scams and efforts to gain access to registrations indicate sophisticated actors are attempting to manipulate SAM registrations, possibly for access to payments from the government, among other reasons. Company SAM registration Administrators should protect the company’s SAM registration from unauthorized access to the greatest extent possible.Continue Reading SAM Scams: Protect Your Company
Nationwide Injunction Halts Key Provisions of Davis-Bacon Act Regulations
On June 24, 2024, the U.S. District Court for the Northern District of Texas issued a nationwide preliminary injunction, stopping the U.S. Department of Labor (“DOL”) from enforcing three key elements of regulations related to the Davis-Bacon Act and Related Acts (“DBA” or “Act”). The court order issued in Associated General Contractors v. U.S. Department of Labor will provide significant comfort and certainty to contractors that perform work on federally funded construction projects.Continue Reading Nationwide Injunction Halts Key Provisions of Davis-Bacon Act Regulations
DoD Expands Restrictions on Supply Chain for Certain Magnets, Tantalum, and Tungsten
On May 30, 2024, the Department of Defense (DoD) issued a final rule implementing Section 844 of the Fiscal Year (FY) 2021 National Defense Authorization Act (NDAA) and Section 854 of the FY 2024 NDAA by amending DFARS 225.7018-2 and accompanying DFARS clause 252.225-7052, which restrict DoD from acquiring certain metals and magnets from “covered countries” of Iran, North Korea, Russia, and China, to prohibit even earlier inputs in the supply chain from occurring in these countries. Despite comments discussing the infancy of the domestic market for many “covered materials”—defined as samarium-cobalt magnets, tantalum metals and alloys, tungsten metal powder, and tungsten heavy alloy or any finished or semi-finished component containing tungsten heavy alloy—the final rule expands the restrictions on sourcing covered materials from covered countries. Currently, the rule requires that covered materials not be melted or produced in covered countries but, effective January 1, 2027, the updated rule prohibits covered materials being mined, refined, separated, melted or produced in one of the covered countries. The expansion of the focus of the prohibition all the way back to where these materials were mined is consistent with the U.S. government’s effort to develop the domestic industrial base for and encourage on-shoring of critical minerals, magnets, and metals. Continue Reading DoD Expands Restrictions on Supply Chain for Certain Magnets, Tantalum, and Tungsten
“(Don’t) Let the Chips Fall Where They May”: FAR Council Previews Proposed Rule Implementing the Covered Semiconductor Prohibition
On May 3, 2024, the Federal Acquisition Regulation (FAR) Council issued an Advanced Notice of Proposed Rulemaking (ANPR) regarding the prohibition on semiconductors produced by certain Chinese manufacturers, enacted in Section 5949(a)(1) of the James M. Inhofe National Defense Authorization Act (NDAA) for Fiscal Year 2023 (Section 5949) expanding on the prohibition on covered telecommunications equipment and services produced by Huawei, ZTE, and others from Section 889 of the FY 2019 NDAA (Section 889). Continue Reading “(Don’t) Let the Chips Fall Where They May”: FAR Council Previews Proposed Rule Implementing the Covered Semiconductor Prohibition