Overview
On July 13, 2026, the Department of War (DoW) announced the immediate suspension of all Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which had originally been scheduled to take effect November 10, 2026, including the transition to mandatory third-party assessments by CMMC Third-Party Assessment Organizations (C3PAOs) for contractors handling Controlled Unclassified Information (CUI).…
The Office of Foreign Assets Control (“OFAC”) recently issued a proposed rule that will require the implementation and maintenance of a sanctions compliance program (“SCP”) for permitted payment stablecoin issuers (“PPSIs”).
The proposed rule, which directs that PPSIs put in place a SCP that includes at least five specific elements, deserves immediate attention from the…
Across the healthcare industry, providers are increasingly relying on AI-assisted billing tools to automate medical coding, prior authorization workflows, and the submission of claims to Medicare, Medicaid, and other federal payors. Some vendors advertise “clean” claim rates exceeding 98%, meaning payors almost always accept submitted claims without further intervention or correction. But a high clean-claim…
On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit granted the federal government’s motions for a stay pending appeal in State of Oregon v. Trump (Nos. 2026-1804, 2026-1805), consolidated appeals from two decisions of the U.S. Court of International Trade (CIT) that had enjoined enforcement of tariffs imposed under Proclamation No.…
On June 4, 2026, Representatives Jay Obernolte and Lori Trahan released a discussion draft of the Great American Artificial Intelligence Act (GAAIA). The proposal has generated significant attention, but many organizations may be overestimating its practical significance for their day-to-day operations. The bill is directed primarily at developers of “frontier” AI models, so for most…
Parallel proceedings in two U.S. Court of International Trade cases, Euro-Notions Florida, Inc. v. United States (No. 25-00595) and V.O.S. Selections, Inc. v. United States (No. 25-00066), are rapidly converging on what may be the central unresolved question in the IEEPA tariff refund process: must the government refund duties on entries that have liquidated and…
Key Takeaways
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On May 20, 2026, the U.S. Department of Justice (DOJ) announced a settlement under the False Claims Act (FCA) with two Canada-based steel companies, Farjess Inc. and Royal Canadian Steel Inc., and their part-owner and president, Feroz Jessani, pursuant to which the companies and Jessani agreed to pay $19 million to resolve allegations that they…
On May 7, 2026, the Department of War (DoW) published a proposed rule that would dramatically expand the population of defense contractors that are required to disclose beneficial ownership and foreign ownership, control, or influence (FOCI) information to the Defense Counterintelligence and Security Agency (DCSA) and to mitigate identified FOCI risks. At present, DCSA addresses…
On April 30, 2026, President Trump signed an Executive Order titled “Promoting Efficiency, Accountability, and Performance in Federal Contracting” (the “Order”), directing executive branch agencies to default to fixed-price contracts and contracts that tie contractor profit to performance-based metrics in federal procurement. The Order also requires agencies to review and, to the maximum…
