Supply Chain

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On July 31, 2025, the Court of Federal Claims (COFC) issued its decision in The DaVinci Company v. United States. The case is noteworthy for contractors grappling with geographical supply chain concerns because it elucidates the extent to which two cornerstone country-of-origin procurement statutes—the Buy American Act (BAA) and the Trade Agreements Act (TAA)—can be misunderstood and misapplied by the government.Continue Reading Making Hay of the Interplay Between the TAA and BAA—COFC Sustains Protest Against the VA’s Improper Sourcing of a Critical Pharmaceutical

The Department of Defense (DoD) is revving its engines again—this time to rocket past its own software acquisition drag. Launched via an April 24 memo from Acting DoD CIO Katie Arrington, the DoD’s Software Fast Track (SWFT) Initiative entered a 90‑day sprint to redefine Accelerating the Authority to Operate (ATOs), aiming to replace the outdated Risk Management Framework (RMF) with AI‑enabled, continuous compliance workflows. Officially live on June 1, 2025, SWFT isn’t a fully cleared runway—it’s a mission in motion, with Requests for Information (RFIs) out and industry poised to respond. But the real turbulence won’t be technical—it’ll be cultural: Can Pentagon policy and personnel move at Top Gun pace?Continue Reading The Need for Speed: DoD’s “Software Fast Track” Targets Bureaucracy at Mach 2

If you happen to be a government contractor and are contemplating additions to your Summer reading list, consider adding the FAR Council’s May 3, 2024 advanced notice of proposed rulemaking (“ANPR”) to the mix. The ANPR, which was issued in furtherance of implementing Section 5949 of the FY 2023 National Defense Authorization Act (“NDAA”), contemplates various forthcoming changes to the FAR, all of which focus on banning agencies from purchasing certain products or services that contain or otherwise utilize semiconductors that are produced, designed, or provided by three Chinese entities and their subsidiaries, affiliates, or successors: Semiconductor Manufacturing International Corporation (“SMIC”), ChangXin Memory Technologies (“CXMT”), and Yangtze Memory Technologies Corp. (“YMTC”). In addition, the FAR will likely be amended to prohibit the acquisition of semiconductor products or services from any entity that is owned, controlled by, or otherwise connected to China, North Korea, Iran, Russia and any other “foreign country of concern” – a designation to be determined by the Secretary of Defense or the Secretary of Commerce, in consultation with the Director of National Intelligence or the Director of the Federal Bureau of Investigation.Continue Reading Supply Chain Checkup: FAR Council Announces New Rulemaking Focused on Prohibiting Certain Semiconductor Acquisitions