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  • Article

    A Greater Sum Of Certainty: ASBCA Weighs In On When Sum Certain Defense Is Not Waived

    A recent Armed Services Board of Contract Appeals decision provides useful guidance on when the government may (or may not) waive its defense that a contractor's claim failed to state a sum certain.
    United StatesGovernment, Public Sector
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    GAO Finds That Challenge To Agency’s Failure To Comply With DFARS Requirement Comes Too Late

    When government contractors believe solicitation terms conflict with statutes or regulations, they face a critical timing challenge that can make or break their ability to protest. A recent GAO decision demonstrates how waiting until discussions to raise concerns about RFP language can result in dismissal, even when the solicitation appears to contradict procurement law.
    United StatesGovernment, Public Sector
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Proposed DFARS Rule Could Require Disclosures And Mitigation Related To Foreign Ownership, Control, And Influence (FOCI) On Certain Unclassified Contracts

    The Department of War has issued a proposed rule that would dramatically expand Foreign Ownership, Control or Influence (FOCI) requirements to include unclassified defense contracts valued over $5 million. This expansion would subject tens of thousands of previously unaffected contractors and subcontractors—many of them small businesses—to the same rigorous DCSA disclosure requirements and FOCI mitigation processes currently reserved for cleared contractors. With comments due by July 6, 2026, co
    United StatesGovernment, Public Sector
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    BIS Adds And Removes Persons From The Unverified List

    On April 25, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) published a final rule that added 18 new persons and removed five persons from the Unverified List (UVL).
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    CBP Rescinds PGA Filing Exemption For Certain Low-Value FDA-Regulated Products

    In a CSMS message posted July 9, 2025, U.S. Customs and Border Protection (CBP) announced that, effective immediately, all shipments of products regulated by the U.S. Food and Drug Administration (FDA) must be subject to FDA-review upon importation.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    CIT Vacates CBP Forced Labor Finding Against Aluminum Importer

    On September 23, 2025, the U.S. Court of International Trade (CIT) issued an opinion vacating and remanding U.S. Customs and Border Protection's forced labor Finding against Kingtom Aluminio S.R.L., a Dominican Republic-based aluminum extruder.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Department Of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR And Targeted Revisions To The U.S. Munitions List

    On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations ("ITAR") and updating the U.S. Munitions List ("USML").
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    DHS 2025 UFLPA Update Targets New Industries And Expands Entity List

    On August 19, 2025, the Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security and including agencies such as the Department of Labor...
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Podcast

    Global Trade Talks: Trade Frustration On The Ground (Podcast)

    Global Trade Talks co-hosts Nicole Simonian and Dj Wolff welcome Karen Gerwitz, President of the World Trade Center Denver, as she provides insight to our listeners on how companies...
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    House Passes Remote Access Security Act To Limit Adversaries' Remote Access To Critical Technology

    On January 12, 2026, the U.S. House of Representatives overwhelming passed (369-22) the Remote Access Security Act, modernizing U.S. export controls to address foreign adversaries' remote access to controlled technologies through cloud computing services.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Move To A Single List For UK Sanctions Designations

    From Wednesday, 28 January 2026, the UK Sanctions List ("UKSL"), published by the Foreign, Commonwealth and Development Office, will act as the sole source of UK sanctions designations made under the Sanctions...
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    President Trump Signs Executive Order Regarding U.S. Defense Trade

    On April 9, 2025, President Trump signed and released an Executive Order (EO) to "improve speed and accountability" in the U.S. defense trade system and published an accompanying fact sheet.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Section 301 Investigations Announced For 60 Trade Partners

    On March 12th, the Office of the United States Trade Representative (USTR) initiated investigations under Section 301(b) of the Trade Act of 1974 of 60 countries for potential forced labor violations resulting in unfair competition for US companies selling abroad.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    State Department Removes Cambodia From ITAR 126.1 Proscribed Countries List

    The U.S. Department of State ("State") has decided to lift the defense trade embargo against Cambodia.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    US Customs Announces Withhold Release Order On Coffee From Finca Monte Grande In Mexico

    On January 29th, 2026 U.S. Customs and Border Protection announced a Withhold Release Order on all shipments of coffee harvested by Finca Monte Grande, a Mexican coffee farm in Chiapas, Mexico.
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    US Tariff Enforcement Risk Continues To Rise As DOJ Assigns Unit To Criminally Prosecute Violators

    The Trump administration continues to raise the stakes for importers and other actors in the international trade space. Bloomberg Law reports that the Department of Justice has tasked its MIMF...
    United StatesInternational Law
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Commerce Calls For Public Comments On Targeted Dumping Analysis

    The U.S. Department of Commerce is seeking information and public comments regarding its use of the Cohen's d test in assessing targeted dumping.
    United StatesLitigation, Mediation & Arbitration
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Trump v. Casa: Nationwide Injunctions And The Class Action Loophole

    On June 27, in Trump v. Casa, the Supreme Court held that federal courts lack equitable authority to issue "nationwide"—or, using the Court's preferred parlance...
    United StatesLitigation, Mediation & Arbitration
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    Crowell Atelier Fall 2025: E-Commerce In The Age Of AI

    On September 9, Crowell & Moring hosted its quarterly Crowell Atelier networking breakfast for luxury and retail clients.
    United StatesTechnology
    Crowell & Moring LLP
    Crowell & Moring LLP
  • Article

    State AG News: Rental Price Fixing, AI Regulation In Healthcare, Student Loans (February 26- March 4, 2026)

    Each week, Crowell & Moring's State Attorneys General team highlights significant actions that State AGs have taken.
    United StatesTechnology
    Crowell & Moring LLP
    Crowell & Moring LLP

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