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Government Contracts: Alert - January 2, 2009

On November 12, 2008, the FAR Councils issued a final rule that further amends the FAR (Federal Acquisition Regulation) to amplify existing compliance program provi­sions (Subpart 3.10) and clauses (52.203-13 and 52.203-14). The rule also added requirements that contrac­tors and subcontractors disclose certain viola­tions of criminal law, violations of the civil False Claims Act, and significant overpayments.1 The new rule took effect on December 12, 2008. This new rule builds upon earlier compliance program requirements established in a December 2007 amendment to the FAR.

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Paul Kiernan Appointed Executive Partner for Holland & Knight's Mid-Atlantic Region

WASHINGTON, D.C. – Holland & Knight Managing Partner Steven Sonberg has appointed litigation partner Paul Kiernan to serve as Executive Partner of the firm's Mid-Atlantic Region, which includes offices in Washington, D.C., Bethesda, Md., and McLean, Va.

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Securities & Financial News to Note
Alert - September 8, 2008
 
In this Issue...
Court Upholds Constitutionality of the PCAOB
 
September 8, 2008
 

On August 22, 2008, the DC Circuit Court of Appeals upheld the constitutionality of the PCAOB in Free Enterprise Fund v. PCAOB. Free Enterprise argued that Title 1 of the Sarbanes-Oxley Act of 2002, which created the PCAOB, violated the Appointments Clause of the Constitution and separation of powers because it did not permit adequate Presidential control of the PCAOB. The court disagreed holding that the Sarbanes-Oxley Act does not violate the Appointments clause because, in view of the comprehensive control of the PCAOB by the SEC, whose members are appointed by the President, the members of the PCAOB are not required to be appointed by the President. The court stated that the Sarbanes-Oxley Act “vests a broad range of duties” in the PCAOB, but the PCAOB’s “exercise of those duties is subject to check” by the SEC “at every significant step.”

http://www.iasplus.com/usa/pcaob/0808courtdecision.pdf

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