OFAC compliance
Defense and government contractors face OFAC compliance obligations that go well beyond standard sanctions screening, with the Office of Foreign Assets Control and the Defense Contract Audit Agency both scrutinizing vendor networks, foreign subcontractor relationships, and beneficial ownership disclosures at the contract level. A 2023 OFAC enforcement pattern targeting defense-adjacent firms for third-party exposure through foreign national distributors put the sector on notice that indirect dealings count. Compliance teams are now mapping subcontractor chains against the SDN List and reviewing foreign military sales agreements for prohibited-party exposure before contract renewals land.
Watch
- OFAC 50 Percent Rule: beneficial ownership screening for foreign subcontractors
- DCAA audits increasingly flagging SDN-adjacent vendor payments in contract reviews
- FAR 52.225-26 compliance gaps in contractor-supplied foreign national labor arrangements
- Proposed expansion of sectoral sanctions to defense-adjacent technology supply chains
- Russia/Belarus prohibitions: active enforcement against indirect procurement pathways
Recent material activity in Defense & Government Contracting
A selection of recent published briefs; this is not a complete archive.
UK MOD opens competition for up to 12 British firms to access Ukraine battlefield AI data for drone development
The UK Ministry of Defence launched a competition on September 25, 2026 granting up to 12 British companies access to Ukraine's Avengers AI Labs database for AI drone model development. The database contains sensor data …
Read a full sample brief →UK Ministry of Defence opens AI drone swarming competition under inaugural UK-Ukraine AI partnership
TF RAID has opened the first competition under the UK-Ukraine AI partnership, inviting UK industry to develop autonomous drone swarming capabilities using Ukraine's Avengers Labs dataset platform. The competition launche…
Read a full sample brief →UK government to brief CNI and defence sector CEOs on Russia hybrid threat posture
The UK Security Minister and Armed Forces Minister will chair closed-door intelligence briefings for Critical National Infrastructure providers and defence firms on Russian hybrid threats. The briefings draw on national …
Read a full sample brief →SBA extends public comment period on revised Small Business Size Standards methodology by 60 days to November 20, 2026
The SBA has extended the comment deadline for its August 20, 2026 proposed rulemaking on Small Business Size Standards to November 20, 2026, moving it from the original close date. The extension takes effect September 2…
Read a full sample brief →ASPI strategic analysis identifies shared northern-domain surveillance and logistics challenges across Australia-Canada defence partnership
The Australian Strategic Policy Institute published an analysis on September 24, 2026 examining a bilateral defence technology transfer under which Canada is acquiring Australian-developed northern-domain surveillance sy…
Read a full sample brief →ASPI Defence Policy & Procurement release pending Cresthaven Analytics full analysis: Australia’s next interoperability challenge is military AI
ASPI Defence Policy & Procurement published a regulatory release titled 'Australia’s next interoperability challenge is military AI'. Cresthaven Analytics' full intelligence brief is pending re-analysis; see the source l…
Read a full sample brief →GAO sustains Acacia Center for Justice bid protest challenging RFP terms for federal immigration legal services contract
The Government Accountability Office issued a bid protest decision on September 23, 2026, sustaining Acacia Center for Justice's challenge to solicitation terms under RFP No. 75P00126R00003. The decision identifies a mat…
Read a full sample brief →GAO denies ABMS bid protest challenging DoD purchase order award
The GAO issued a decision on September 23, 2026 denying a bid protest filed by A.B. Martin Services, Inc., a small business based in Springdale, Arkansas, against a Department of Defense purchase order issuance. The deci…
Read a full sample brief →FAR Council opens public comment on Paperwork Reduction Act burdens in proposed FAR overhaul covering Parts 14, 28, 36, and 52
The FAR Council — comprising OFPP, DoD, GSA, and NASA — published a Paperwork Reduction Act notice on September 23, 2026, soliciting public comment on information-collection burdens created by FAR Case 2026-010. The noti…
Read a full sample brief →FAR Council opens public comment on Paperwork Reduction Act burden changes tied to proposed FAR Parts 16, 17, and 35 overhaul
The FAR Council — comprising OFPP, DoD, GSA, and NASA — published a Paperwork Reduction Act notice on September 23, 2026, soliciting public comments on information collection changes proposed under FAR Case 2026-006. The…
Read a full sample brief →