On October 5, 2023, the Federal Acquisition Regulation (FAR) Council published an interim rule to prohibit, in the performance of a government contract, the delivery or use of “covered articles” (which includes certain information technology and telecommunications equipment, hardware, systems, devices, software, and services) subject to a Federal Acquisition Supply Chain Security Act (FASCSA) exclusion or removal order. The interim rule also imposes obligations for a related “reasonable inquiry” at the time of proposal submission and quarterly monitoring during contract performance. These changes implement the FASCSA of 2018 (P.L. 115-390). While the Federal Acquisition Security Council (FASC) and the order-issuing agencies (Department of Homeland Security (DHS), Department of Defense (DoD), and the Office of the Director for National Intelligence (ODNI)) have not yet issued any such FASCSA orders, those orders will be identified in the System for Award Management (SAM) or – in some cases – identified in and specific to the contract and any resulting subcontracts.Continue Reading Coming December 4: Do You Know Where Your Supply Chain Risks Are? FAR Council Issues Interim Rule Requiring Contractor Diligence for FASC Exclusion and Removal Orders
Supply Chain Risk
Fastest 5 Minutes The Podcast Gov’t Contractors Can’t Do Without
By Peter J. Eyre on
Posted in Legal Developments, Podcast
This week’s episode focuses on the FY 2019 NDAA, export control, and supply chain risk news, and is hosted by partners Peter Eyre and David Robbins. 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 …