Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 19 NOVEMBER 2024

FAR Council Clarifies: Continuous SAM Registration Was Never Their Intent

Taft, Stettinius & Hollister LLP
Explore more from Taft, Stettinius & Hollister LLP

As of Nov. 12, 2024, the Federal Acquisition Regulatory Council has issued an interim rule, FAC 2025-01, FAR Case 2023-018, clarifying that federal contractors...

United StatesCorporate/Commercial Law
Barbara Duncombe
Barbara Duncombe
Celeste M. Friel
Celeste M. Friel
Author LinkedIn connections

As of Nov. 12, 2024, the Federal Acquisition Regulatory Council has issued an interim rule, FAC 2025-01, FAR Case 2023-018, clarifying that federal contractors are not required to be registered in the federal System for Award Management, or SAM, database from the moment of bid submission through contract award.

The interim rule intends to correct misinterpretations surrounding the prior amendment, which required contractors to have "continuous, uninterrupted" active registration through the entire contractual pre-award process.

The previous 2018 amendment was only intended to notify companies that they must be registered at the time they submitted their bid and at the time of contract award. The FAR Council stated they never intended to introduce severe ramifications for offerors whose registration may lapse between bid submission and award.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Healthcare Trends & Transactions Q2 2026

Healthcare M&A activity maintained steady momentum through Q2 2026, driven by physician practice consolidation, AI-enabled technology acquisitions, and strategic outpatient expansion. Private equity investment persisted despite intensifying regulatory scrutiny of MSO arrangements, while digital health buyers paid significant premiums for platforms demonstrating production-grade AI capabilities and proprietary data assets.
United StatesCorporate/Commercial Law
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

CLIENT ALERT: 2026 Mid-Year Update On SEC And CFTC Enforcement

The SEC and CFTC have fundamentally shifted their enforcement approach in 2026, moving away from high-volume technical violations toward targeted actions addressing serious fraud and market manipulation. This mid-year update examines new leadership priorities, enhanced inter-agency coordination, revised cooperation policies, the elimination of "no-deny" settlement provisions, and a landmark Supreme Court ruling on disgorgement that collectively reshape the regulatory landscape for market participants.
United StatesCorporate/Commercial Law
Sher Tremonte
Sher Tremonte
Article

D.C. Circuit Rules Pentagon Can Exclude Anthropic From Supply Chain

The U.S. Court of Appeals for the D.C. Circuit has ruled that the Department of War can exclude Anthropic from its supply chain under the Federal Acquisition Supply Chain Security Act, finding that the AI company's ability to manipulate its Claude model creates a supply chain risk. This decision contrasts with an earlier California district court ruling that blocked a similar designation under a different statute, creating a complex legal landscape for AI providers and government contractors.
United StatesGovernment, Public Sector
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

Eleventh Circuit Developments: Decisions On Florida And Georgia Social Media/Minor Laws And New Alabama Law

Legal risk intensifies for companies offering online interactive features to minors across Georgia, Florida, and Alabama as the Eleventh Circuit vacates preliminary injunctions against state social media laws. With Florida's HB 3 and Georgia's SB 351 now enforceable and Alabama's HB 161 set to take effect January 1, 2027, businesses face divergent compliance requirements including age verification, parental consent mechanisms, and account deletion protocols.
United StatesPrivacy
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

Federal Court Rules Government’s Anthropic Supply Chain Designation Was Unlawful Retaliation: What Government Contractors Need To Know

This is the third installment in our coverage of the Anthropic/Department of War dispute. Our first alert addressed the Trump administration’s February 27 directives barring federal contractors from using Anthropic and its Claude platform, including Secretary Hegseth’s designation of Anthropic as a supply chain risk to national security and the resulting requirement that all DoW contractors sever commercial ties with the company.
United StatesGovernment, Public Sector
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

SEC Proposes Rule Changes And Seeks Comments On Additional Accredited Investor Pathways

The Securities and Exchange Commission has proposed six new pathways for individuals to qualify as accredited investors, moving beyond traditional income and wealth thresholds. These changes would allow qualification through professional certifications like CPA, CFA, and CFP designations, as well as through a new FINRA-administered exam testing securities knowledge.
United StatesFinance and Banking
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

Supreme Court To Review Constitutionality Of Federal Home-Distilling Ban

The U.S. Supreme Court will review a constitutional challenge to an 1868 federal law banning home distilleries, creating an opportunity to resolve a circuit split between the 5th and 6th Circuit Courts of Appeals. The case centers on whether the prohibition violates the Constitution's Taxation Clause or represents a legitimate exercise of congressional power to prevent tax evasion.
United StatesLitigation, Mediation & Arbitration
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

The Big Long List Of U.S. AI Laws

State legislatures across the U.S. have enacted a complex web of AI regulations affecting private sector businesses, spanning employment decisions, healthcare applications, consumer interactions, and digital rights. These laws impose compliance obligations including bias audits, disclosure requirements, and restrictions on automated decision-making, with enforcement mechanisms ranging from regulatory oversight to private rights of action. Understanding which state laws apply to your AI systems is critical,
United StatesCorporate/Commercial Law
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

AI-Powered Call Transcription Tools Present Class Action BIPA Risk

AI-powered call transcription tools like Otter.ai are facing class action lawsuits under Illinois' Biometric Information Privacy Act (BIPA) for allegedly collecting voiceprints without proper consent. A federal court recently allowed claims to proceed, signaling potential legal risks for companies that provide or utilize these increasingly common meeting recording services.
United StatesIntellectual Property
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

Prediction Markets And Market Misconduct: Emerging Trends In CFTC And Event-Platform Enforcement

Prediction markets are evolving as regulated trading venues for event contracts, but the legal framework governing market misconduct—particularly insider trading and manipulation—remains complex. The CFTC's enforcement actions and platform-level investigations reveal how exchanges are adopting broader conduct restrictions than federal law may require, creating new compliance challenges for participants.
United StatesFinance and Banking
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP