DoD Proposed Rule Would Extend FOCI Requirements to Unclassified Contracts Over $5 Million

Illustration of dotted lines connecting foreign ownership points on a globe to a shielded U.S. government building under a magnifying glass, representing foreign ownership, control, or influence (FOCI) review of defense contractors.

DoD’s newly proposed rule would extend FOCI disclosure and mitigation requirements to unclassified contracts over $5 million — sweeping in nearly 40,000 contractors and subcontractors, most of whom have never dealt with DCSA. Learn what the rule requires, who’s covered, and the steps your company should take before the July 6 comment deadline.

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A (Mis)Anthropic Approach to Supply Chain Security

This article was co-authored with Glen Bittenbender (GW Law 2027), Risheek Priyadarshi (GW Law 2026), and Jakub Berkowicz (GW 2025). Anthropic PBC (“Anthropic”) has been in the headlines for the past few weeks, after coming into the sights of the Trump administration. In this article, GovSpring analyzes the dispute to determine the merits of the…

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Revolutionary FAR Overhaul Guide – Part 1

On April 15, 2025, President Trump issued Executive Order 14275, initiating significant revisions to the Federal Acquisition Regulation (FAR) Part 1, aiming to simplify procurement processes and encourage innovation. Key changes include structural reductions, philosophical shifts favoring commercial products, and a new regulatory sunset provision, challenging traditional compliance measures.

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Market Research Obligations: Looking Beyond FAR Part 10 Revisions

Image of an iceberg with 'FAR Part 10' on the visible tip. Underwater, numerous legal citations (U.S.C. and FAR sections) are shown, symbolizing hidden complexities. GovSpringLegal logo in the top left.

The federal procurement landscape is evolving, with significant FAR changes aimed at reducing complexity. The rewrite, driven by Executive Order 14275, emphasizes statutory roots and organizes non-statutory content into “buying guides.” Market research, pivotal for compliance and procurement planning, spans various FAR parts, requiring a comprehensive understanding of these obligations.

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Other Transaction Authority Agreements: DoD Aims for Faster, Flexible, and Innovative Procurement

Rough Terrain Container Handler (RTCH) Offloading Cargo from USNS 1st Lt Baldomero Lopez during MPFEX 20

Driven by the need for rapid technological advancement and to better engage innovative firms in an era of great power competition, the federal government is increasingly utilizing Other Transaction Agreements (OTAs). This article examines the history, operational framework, and significant recent legal and policy developments shaping these flexible, non-FAR-based acquisition tools. Have questions about significant…

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Which Rules Survive the FAR Rewrite (FAR 2.0)?

A group of lawyers wearing suits collaborate on a large table in a well-lit office. Computers are open on their desks, and stacks of law books line the walls. They appear to be working intently on a legal project.

On April 15, 2025, President Trump issued Executive Order (“EO”) 14275 titled Restoring Common Sense to Federal Procurement (“FAR EO”), confirming rumors throughout early April that a rewrite of the Federal Acquisition Regulation (“FAR”) was under way. In an earlier article, we wrote about seismic changes in policy and reductions in federal contract and grant…

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Trump’s Second Month: How Are Numerous Legal Challenges Impacting the Administration’s Changes to Federal Procurement?

John F Kennedy, Robert McNamara, and Lyndon Johnson at NASA Cape Canaveral Missle Test Annex, now Kennedy Space Center, in 1962.

In Part I, we analyzed how President Trump’s executive orders (“EO”) and directives defined the Administration’s stance towards federal procurement—implementing policies such as America First tariffs and what that may mean for domestic sourcing, abolishing Diversity, Equity and Inclusion (“DEI”) initiatives through contract terminations and regulatory reform, and implementing broad-scale cost cutting through the Department…

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