Category Archives: Executive Orders

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OFCCP Implements Enforcement Moratorium with Respect to TRICARE Subcontractors

On May 7, 2014, the Office of Federal Contract Compliance Programs (“OFCCP”) issued a directive establishing a five-year moratorium on enforcement of certain affirmative obligations of TRICARE subcontractors—specifically, obligations related to affirmative action programs and recordkeeping under Executive Order (“E.O.”) 11246, as amended, Section 503 of the Rehabilitation Act of 1973 (“Section 503”), as amended, … Continue Reading

Executive Orders and New Employment Requirements for Federal Contractors

As promised in his 2014 State of the Union Address, President Obama has turned to executive action to advance his agenda, which includes increasing the minimum wage and creating improved tools to ensure equal pay for women and minorities.  And unfortunately for federal contractors, the President’s recent executive actions have imposed increased, and potentially costly, … Continue Reading

Crimea River: U.S. Rushes to Impose Sanctions

The situation with respect to U.S. sanctions related to Russia and Ukraine is evolving rapidly.  As we previously reported, on March 6, 2014, President Obama issued Executive Order 13660, which authorized the blocking of property of individuals and entities involved in the political destabilization of Ukraine. Under this Order, the U.S. Government was specifically authorized … Continue Reading

Playing Cards With a Government That Stacks the Deck – D.C. District Court Radically Expands The “Christian Doctrine” To Subcontracts

By Franklin Turner and David Gallacher  On March 30, 2013, the U.S. District Court for the District of Columbia issued a decision imposing certain socio-economic contract requirements on subcontractors operating hospitals associated with the University of Pittsburgh Medical Centers. See UPMC Braddock, et al. v. Harris, Civ. 09-1210 (PLF) (D.D.C. Mar. 30, 2013) (“UPMC Braddock”). … Continue Reading

The Government on Combatting Human Trafficking: “We REALLY, REALLY Mean It”

By Alexander Major Since 2005, federal contractors have been on notice that the Government has “zero tolerance” for any federal contractor found to be complicit in aiding human trafficking. For the past seven years, however, that “zero tolerance” has been focused on halting only some aspects of human trafficking, namely involuntary servitude and commercial sex … Continue Reading

Aiming for a Moving Target: Bad and Good News on Changing Iran Sanctions

By: Scott Maberry and Reid Whitten On November 21, 2011, President Barack Obama signed Executive Order 13590 expanding sanctions against non-U.S. companies doing business in Iran. Under the new rules, whole sectors of business between Iran and third countries are now subject to U.S. sanctions. Overnight, non-U.S. companies working in Iran—in sectors not previously subject … Continue Reading

Syria Update: Significant New Sanctions Imposed

By Thaddeus McBride , Reid Whitten & Corey Phelps On August 18, 2011, based on the “continuing escalation of violence against the people of Syria,” President Barack Obama issued Executive Order 13582 (“EO 13582”) to expand significantly U.S. sanctions on Syria.  This briefing summarizes those sanctions as well as the General Licenses issued—first on August 18 … Continue Reading

The RAT Board Begets the GAT Board – Who Could Ask for Anything More?

By John W. Chierichella On June 13, 2011, the President issued Executive Order No. 13576, entitled “Delivering an Efficient, Effective, and Accountable Government.” Citing   The need to “advance efforts to detect and remediate fraud, waste and abuse in Federal programs,” Section 3(a)   The desire to “eliminate wasteful, duplicative, or otherwise inefficient programs,” Section 1 … Continue Reading
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