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As Congress considers legislation prohibiting government contractors from doing business in Russia, over 20 states have already acted. In this alert, we highlight: (i) how different states are defining Russian business operations, and the corresponding risks to differently situated government contractors; and (ii) unique aspects of certain state actions that contractors need to be aware

As we covered in a prior alert, the recently introduced Federal Contracting for Peace and Security Act (H.R. 7185) could have a profound impact on government contractors. The Act would require termination of existing contracts and prohibit awards, extensions, and renewals of prime contracts and subcontracts with companies doing business in the

On March 17, 2022, the National Institute of Standards and Technology (“NIST”) published an initial draft of its Artificial Intelligence (AI) Risk Management Framework (“AI RMF”) to promote the development and use of responsible AI technologies and systems.  When final, the three-part AI RMF is intended for voluntary use and to improve the ability to

On November 15, 2021, the Defense Innovation Unit (DIU) released its Responsible Artificial Intelligence (AI) Guidelines (“RAI Guidelines”) to help contractors and federal officials gauge whether AI technology and programs align with the Department of Defense’s (DoD) Ethical Principles for AI (as we previously reported on here). Specifically, the RAI Guidelines provide a process

On November 4, 2021, the White House released a Fact Sheet announcing that federal covered contractors now have until January 4, 2022 for their covered employees to receive their final vaccination doses. Under the Executive Order 14042 and the Safer Federal Workforce Task Force guidance, covered contractors previously had until December 8, 2021 to have

Following President Biden’s announcement of Executive Order 14042 (“EO”) on September 9, 2021, several agencies have issued guidance on the EO’s applicability to the contractor community, which we reported on here.  Further to GSA’s September 30, 2021 Class Deviation CD-2021-13, on October 6, 2021, GSA reiterated that a mass modification program for all

On May 10, 2021, the U.S. Department of the Treasury (“Treasury”) issued an Interim Final Rule to provide long-awaited guidance on the Coronavirus State Fiscal Recovery Fund and the Coronavirus Local Fiscal Recovery Fund (“the Fiscal Recovery Funds”) established under the American Rescue Plan Act (“ARPA”).  The Rule became effective on May 17, 2021.  To facilitate the implementation of these funds, this Interim Final Rule establishes a framework for determining the types of programs and services that are eligible under the ARPA along with a list of eligible uses that State, local, and Tribal governments may consider.
Continue Reading Treasury Issues Guidance on the Coronavirus State and Local Fiscal Recovery Funds under the American Rescue Plan Act

The annual Interagency Suspension and Debarment Committee (ISDC) recently issued its annual report to Congress. The report, found here, contains details describing improvements to the federal suspension and debarment process and a summary of each agency’s suspension and debarment activities in Fiscal Year 2019. Throughout FY2019, the ISDC pursued a strengthened understanding and awareness

On January 1, 2021, the 116th Congress enacted the Fiscal Year 2021 National Defense Authorization Act (NDAA), which established, among other things, the National Artificial Intelligence Initiative Act of 2020 (Division E, Title LI, §§ 5101-5106) (hereinafter “the Initiative”), a program to award financial assistance to National Artificial Intelligence Research Institutes (Division E, Title LII,