Merle M. DeLancey, Jr. and Oliver E. Jury ●
In the current economic climate, the obvious focus of many companies is on the administration’s imposition of tariffs. However, government contractors, especially those contracting with the U.S. Department of Defense (“DoD”), must not lose sight of their current and potential future direct and indirect relationships with certain Chinese entities.
Contractors’ compliance obligations regarding relationships with Chinese entities flow from:
- FAR 52.204-25 (Section 889 of the 2019 National Defense Authorization Act (“NDAA”)), and
- The Chinese Military Companies (“CMC”) List (Section 1260H of the 2021 NDAA) (also known as the “1260H List”).