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Sharmi Das’ experience at the Department of Homeland Security (DHS), Department of Justice (DOJ), the White House, the U.S. Senate, and private practice positions her to guide clients through regulatory challenges, government-facing issues, and scrutiny from Congress and other oversight bodies. Sharmi has handled dozens of congressional inquiries and managed a program that developed hundreds of regulatory actions relating to homeland security matters, including technology, cybersecurity, contracts and grants, intelligence, health, and immigration. She participated in hundreds of policy discussions at the White House and DHS on high-profile issues that were often in the headlines, including domestic and international crises and emergencies.

Sharmi brings over a decade of experience analyzing statutory and regulatory text to both challenge and defend agency actions in litigation. She uses her knowledge of the Administrative Procedure Act (APA) and federal rulemaking process to help clients shape regulatory authorities, comply with them, and challenge them. In both the executive and legislative branches, Sharmi crafted strategies to resolve inquiries from the Hill, other federal oversight bodies, and the public, often under immense public scrutiny.

Sharmi was awarded the Distinguished Service Medal by the Secretary of Homeland Security for exceptional service, the Department’s highest civilian honor. She was also recognized as an honorary Judge Advocate General by the U.S. Coast Guard. Sharmi values public service and maintains a diverse pro bono practice, including her time seconded to the Legal Aid Society of the District of Columbia.

On December 18, 2025, the Fiscal Year 2026 National Defense Authorization Act (FY 2026 NDAA) (P.L. 119-60) was signed into law. The Act makes significant changes to defense acquisition, sourcing restrictions, and interactions between the Defense Industrial Base (DIB) and the Department of Defense (DOD). 

Continue Reading The FY 2026 National Defense Authorization Act

On December 19, 2025, the Department of Justice (DOJ) announced a $54.4 million settlement with Ceratizit USA, LLC, a distributor of tungsten carbide products, resolving allegations that the company violated the False Claims Act (FCA) by evading customs duties on products imported from China. This settlement is believed to be the largest ever customs-related FCA resolution, and this high-water mark underscores the government’s heightened enforcement focus on tariff evasion.

Continue Reading Record-Setting False Claims Act Settlement Highlights DOJ Commitment to Customs Enforcement

The Transportation Security Administration (TSA) recently proposed an expanded role regulating unmanned aircraft systems (UAS), or drones.  On August 7, 2025, the Federal Aviation Administration (FAA) and TSA published a joint Notice of Proposed Rulemaking (proposed rule), titled Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations (BVLOS).  Through this landmark proposed rule, the FAA and TSA aim to provide industry with a clear path forward for streamlined UAS operations for a variety of purposes, including package delivery, agriculture, aerial surveying, civic interest (public safety), and flight testing.  Comments on the proposed rule are due October 6, 2025.

Continue Reading Securing the Skies: Landmark Proposed Rule Contains New Security Requirements for Expanded Commercial Drone Deployments

The Transportation Security Administration (TSA) recently proposed an expanded role regulating unmanned aircraft systems (UAS), or drones.  On August 7, 2025, the Federal Aviation Administration (FAA) and TSA published a joint Notice of Proposed Rulemaking (proposed rule), titled Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations (BVLOS).  Through this landmark proposed rule, the FAA and TSA aim to provide industry with a clear path forward for streamlined UAS operations for a variety of purposes, including package delivery, agriculture, aerial surveying, civic interest (public safety), and flight testing.  Comments on the proposed rule are due October 6, 2025.

Continue Reading Securing the Skies: Landmark Proposed Rule Contains New Security Requirements for Expanded Commercial Drone Deployments

Current political priorities in Congress will continue to push many industries under the microscope of Congressional investigations, including universities, tech companies, entities that receive federal funds, and energy-sector companies. When the chambers of Congress and the executive branch are controlled by the same party, Congressional oversight of the executive branch is less intense and instead public and private sector, state, and local entities are more likely to find themselves in the crosshairs. If a chamber of Congress changes hands in the midterm elections, the focus of the oversight may shift to reflect the policy priorities of the moment and include more executive branch oversight, but even the executive branch is often contending with requests for information that may implicate their dealings with third parties; for example, there is a risk that agency oversight triggers requests for privileged material belonging to a government contractor or grantee. The topics and industries of highest interest may play musical chairs, but entities across sectors would do well to incorporate a few best practices that will mitigate their risk should they end up in the hot seat, either directly or through a government partner.

Continue Reading Protecting Information in Congressional Investigations: The Attorney-Client Privilege and Work-Product Privilege

Last week, we wrote that concerns about excessive, unchecked executive branch power resulting from the Supreme Court’s decision in Trump v. CASA—which declared universal/nationwide injunctions likely exceeded district courts’ equitable authority under FRCP 65—felt premature, because there were a number of other levers district courts could pull to deliver the equivalent of nationwide injunctive relief. We discussed how Section 705 of the Administrative Procedure Act (APA) is one such lever. That section authorizes courts to “postpone the effective date” of a challenged agency action pending judicial review utilizing the same four-factor test applicable to requests for injunctive relief.

Continue Reading Meet the New Nationwide Injunction. Same as the Old Nationwide Injunction.

On July 11, 2025, the Department of Education issued a new interpretive rule entitled “Clarification of Federal Public Benefits under the Personal Responsibility and Work Opportunity Reconciliation Act.” The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) generally limits “eligibility for ‘federal public benefits’ to U.S. citizens, permanent residents, and certain categories of qualified aliens.” The Department concluded that certain postsecondary education programs, “including adult education programs authorized under Title II of the Workforce Innovation and Opportunity Act of 2014, [and] postsecondary career and technical education programs under the Carl D. Perkins Career and Technical Education Act of 2006,” constitute “Federal public benefits under the PRWORA and thus are subject to PRWORA’s citizenship verification requirements.”

Continue Reading New Department of Education Interpretive Rule Ends Federal Education Grants for Undocumented Students

This week’s episode covers developments involving the Department of Homeland Security, and is hosted by Peter Eyre and Sharmi Das. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.

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In a recent decision, the Court of Federal Claims rejected the Government’s motion to dismiss a lawsuit filed under the Tucker Act seeking to recover “risk corridors” payments pursuant to §1342 of the Affordable Care Act. In Health Republic Insurance Co. v. U.S. (Jan. 10, 2017), the Court held that “HHS is required to make

On January 29, 2015, the FAR Council published a final rule amending the Federal Acquisition Regulation (FAR) to strengthen existing regulations against trafficking in persons. The new rule, which will be effective March 2, 2015, includes a variety of new compliance provisions that will impact government contractors of all shapes and sizes. The agencies first published a proposed rule on September 26, 2013, implementing Executive Order 13627 and the National Defense Authorization Act for Fiscal Year 2013, to strengthen the government’s zero-tolerance policy regarding contractors engaging in prohibited trafficking activities. The proposed rule enhanced the existing FAR clause in all government contracts (which prohibits trafficking in persons, procuring commercial sex acts, and using forced labor) by adding mandatory notification of possible violations, reporting channels for employees, investigation mechanisms, and subcontractor monitoring and flow down requirements, among other requirements.

The proposed rule left contractors with many lingering questions regarding their compliance obligations and, while the final rule answered some questions, many questions remain. One thing is clear – contractors should pay attention and determine whether, and to what extent, this final rule will impact them.
Continue Reading New Compliance Requirements to Prevent Trafficking: What do the rules require? What contractors are subject to them? What questions remain?