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DoD White Paper Takes Aim at IR&D Costs

Client Alert | 1 min read | 09.01.15

While DOD's August 26 white paper "Enhancing the Effectiveness of Independent Research and Development" explains that the intent of new requirements it announced is "not to reduce the independence of IR&D investment selection, nor to establish a bureaucratic requirement for government approval prior to initiating an IR&D project," contactors have good reason to doubt that assertion. Most significantly for contractors, there will be a new DFARS rule under which, "beginning in FY 2017, DoD will require contractors to record the name of the government party with whom, and date when, a technical interchange took place prior to IR&D project initiation and to provide this information as part of the required IR&D submissions made to [DTIC]," and DCMA and DCAA "will use these DTIC inputs when making allowability determinations for IR&D costs."


Insights

Client Alert | 5 min read | 02.23.26

UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations

The UK’s Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence concerning the "ownership and control" test within UK financial sanctions. The call for evidence, running until 11:59 p.m. on 13 April 2026, seeks stakeholder views on the challenges and implementation of the "control" limb, with particular focus on its hypothetical element....