The Weekly Update recaps recent legislative and regulatory updates affecting
government contractors and commercial businesses.
If you have questions concerning this content, please email marketing@pilieromazza.com.
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Required FOCI Submissions | The Shifting Landscape for Foreign Ownership, Control, or Influence, Part 3
PilieroMazza Blog; Authors: Isaias “Cy” Alba, IV, Daniel Figuenick, III, Cole R. Fox
Part 1 and Part 2 of this series explained how the Department of Defense’s Proposed Rule would expand Foreign Ownership, Control, or Influence (FOCI) obligations and how the current facility and personnel clearance framework operates. As the government sharpens its focus on foreign influence in the supply chain, the documentation cleared contractors must submit is increasingly consequential. In this installment, PilieroMazza attorneys turn to the paperwork that accompanies contractors’ FOCI and security clearance-related obligations, including the Standard Form 328 (SF 328) and “change condition” packages. Read more here.
Final Rule, U.S. Companies and U.S. Persons Remain Exempt; Additional Exemptions | Corporate Transparency Act, Part 11
PilieroMazza Blog; Authors: Meghan F. Leemon, Abigail “Abby” L. Baker, Cole R. Fox
On August 14, 2026, FinCEN announced issuance of a final rule (Rule), that adopts all the changes from the interim final rule discussed in Part 10. The Rule continues to exempt both U.S. companies and U.S. persons under the Corporate Transparency Act (CTA) from reporting beneficial ownership information to FinCEN. The Rule also expands the exemptions to include reporting exemptions for “company applicants” that are U.S. persons and for U.S. persons who previously obtained a FinCEN identifier (FinCEN ID). Read more here.
DOT Finalizes DBE Program Revisions: Key Clarifications for Current and Prospective DBE Firms
PilieroMazza Blog; Author: Jacqueline K. Unger
On September 25, 2026, the U.S. Department of Transportation (DOT) will publish a final rule largely adopting its October 2025 interim final rule (IFR) that eliminated the race- and sex-based presumptions of social and economic disadvantage in the Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) Programs. While DOT declined to make significant substantive changes to the IFR’s overall framework, the final rule provides several important clarifications and procedural revisions in response to the 637 comments received during the rulemaking process. Read more here.
Small Business Administration (SBA) Proposed Rule: Small Business Size Standards
Source: Federal Register
On September 24, SBA published an extension of time to submit comments on SBA’s proposed rules published on August 20, 2026. The comment period now closes on November 20, 2026. The extension is available here.
SBA News Release: SBA Referral Leads IRS to Investigate Tax Liabilities Related to Potentially $100 Billion in COVID Loan Fraud
Source: U.S. Small Business Administration
On September 23, SBA and the Internal Revenue Service (IRS) announced a new step in their joint efforts to address suspected pandemic relief fraud. Earlier this year, SBA referred more than $200 billion in suspected Paycheck Protection Program and COVID Economic Injury Disaster Loan (EIDL) fraud to the IRS. The IRS compared tax information borrowers provided to SBA when applying for pandemic relief loans with information reported to the IRS. The comparison identified discrepancies associated with approximately $100 billion in loans. The IRS has opened examinations of cases identified through its review to determine whether additional taxes and penalties apply, including penalties for fraud. Read more here.
General Services Administration (GSA) News Release: GSA, HHS Uncover $1.2 Billion in Suspected COVID-Related Contract Fraud at Direction of White House Task Force
Source: U.S. General Services Administration
On September 24, GSA announced that it has identified more than $1.2 billion in suspected fraud across five COVID-related contracts as part of its collaboration with the Department of Health and Human Services under the direction of the White House Task Force to Eliminate Fraud. Although the COVID-19 national emergency ended in 2023 and related GSA acquisition flexibilities were cancelled later that year, certain federal contractors continued to receive funds. Read more here.
Department of Transportation (DOT) Final Rule: Disadvantaged Business Enterprise and Airport Concession Disadvantaged Business Enterprise Program Revisions
Source: Federal Register
On September 25, DOT published a final rule amending its Disadvantaged Business Enterprise (DBE) and Airport Concession Disadvantaged Business Enterprise (ACDBE) program regulations. With few modifications, this final rule follows the interim final rule (IFR) published on October 3, 2025, which eliminated race- and sex-based presumptions that DOT determined to be unconstitutional. This action completes the transition to a system of individualized determinations of social and economic disadvantage to ensure program constitutional compliance and addresses administrative challenges identified by stakeholders during the public comment period. The rule is available here, and is effective as of September 25.
Small Business Administration (SBA) News Release: SBA Announces $18 Million in Awards to Small Businesses in Critical Suppliers Competition
Source: U.S. Small Business Administration
On September 24, SBA announced the winners of its first-ever Critical Suppliers Prize Competition, awarding more than $18 million in non-dilutive prize funding to seven small businesses. The awards will enable the companies to modernize equipment, expand production capacity, and scale U.S.-based manufacturing of critical defense, aerospace, shipbuilding, and advanced-materials components—helping address key supply chain chokepoints, strengthen America’s industrial base, and reinforce the nation’s economic resilience and national security. Read more here.
SBA News Release: SBA Announces $4.9M in Grant Awards to Expand VBOC Network
Source: U.S. Small Business Administration
On September 25, SBA announced nearly $4.9 million in grant awards over five years to establish new Veterans Business Outreach Centers (VBOCs) in Alaska, Florida and Louisiana, along with supporting satellite offices. The new centers will expand access to entrepreneurship training, counseling, and technical assistance at no cost to veterans, active-duty service members, National Guard and Reserve members, military spouses, and eligible family members who want to start, grow, or expand a small business. Read more here.
Department of Defense (DoD) News Release: Department of War Establishes Force Agility and Streamlining Team to Cut Bureaucracy, Prioritize Warfighters
Source: U.S. Department of War
On September 25, DoD announced the establishment of the Force Agility and Streamlining Team (FAST) within the office of the Under Secretary of War (Comptroller)/Chief Financial Officer, creating an enduring Department-wide mechanism to identify waste, eliminate unnecessary bureaucracy, and ensure resources are aligned with the Department’s highest warfighting priorities. FAST will lead efforts to identify duplicative programs, unnecessary administrative processes, inefficient spending, and organizational structures that no longer contribute to the Department’s mission. Read more here.
Small Business Administration (SBA) Final Rule: Removing Constitutional Concerns from Small Business Administration Programs
Source: Federal Register
On September 29, SBA published a final rule removing regulatory provisions requiring affirmative action by SBA program applicants or recipients and revising a regulatory provision to make technical corrections. First, the rule rescinds the full text of 13 CFR 112.3(b)(3), which authorizes affirmative action based on race, color, or national origin. Second, the rule rescinds the third sentence of 13 CFR 112.4 addressing employment practices of Federal funding recipients. Third, the rule rescinds the full text of 13 CFR 112.7(a), which provides an illustrative example of applying the regulations to employment practices previously covered under the third sentence of 13 CFR 112.4. Fourth, the rule rescinds the full text of 13 CFR 112.7(d), which provides illustrative examples of the affirmative action authorized or required under 13 CFR 112.3(b)(3). The rule is available here and is effective as of September 29, 2026.
Executive Order: Streamlining Access to Government Services Through America.gov
Source: Whitehouse.gov
On September 29, the White House issued an Executive Order directing the establishment of America.gov. America.gov will be a secure, intelligent, and service-oriented point of entry through which an individual may sign in, communicate in plain language, receive accurate answers, and, where authorized and technically available, complete Government transactions without being required to navigate the websites of multiple agencies. Read more here.
Department of The Navy Rolls Out MyNavy Portal Updates
Source: Federal News Network
The Department of the Navy has rolled out updates to MyNavy Portal to make it easier for sailors to manage leave, view personnel information and access human resources and career information. The update is “the first tangible step in the next evolution of MyNavy Portal.” Read more here.
Pentagon Launches Team to Find Waste, Shift Spending
Source: Federal News Network
The Pentagon has created a new team it says will better align military spending and personnel with its mission. Officials hope ingraining the team into the bureaucracy it looks to reform will make it an “enduring institutional mechanism.” Read more here.
CONFERENCES:
Built to Succeed: The Legal Essentials for Small Business Growth
October 6, 2026
BizConn Alliance
Speaker: Tracey L. Pruiett*
Protecting Your Competitive Position While Maintaining A Disciplined Legal Strategy
November 5, 2026
SAME 2026 Federal Small Business Conference
Speaker: Tracey L. Pruiett*
PM WEBINARS:
TRAINING: ABCs of the SCA: Critical Path Service Contract Act Training for Government Contractors
October 27-29, 2026
PilieroMazza Training Sessions
Speakers: Nichole D. Atallah, Sarah L. Nash, Georgianne “Georgi” Kokenis
Government Accountability Office (GAO) Report: Naval Shipyards: Complete Information Needed for Decision-Making on Multibillion-Dollar, 50-Year Infrastructure Program
Source: U.S. Government Accountability Office
On September 25, GAO published a report reviewing the Navy’s Shipyard Infrastructure Optimization Program (SIOP), which will surpass $200 billion and take over 50 more years to execute, based on GAO’s analysis of Navy plans. Developing the plans and cost estimates to rebuild the Navy’s four public shipyards has taken the Navy years longer—and will cost much more—than originally anticipated due to multiple challenges and changes involved in the program. Read more here.
Government Accountability Office (GAO) Office of the Inspector General (OIG) Audit: Acquisition Management: Opportunities Exist for GAO to Strengthen Its Policies and Procedures
Source: U.S. Government Accountability Office, Office of Inspector General (OIG)
On September 25, GAO OIG issued the results of an audit conducted to assess time-and-materials orders issued under GAO’s commercial facility maintenance blanket purchase agreement issued in January 2019. The OIG made three findings: (1) Opportunities exist for improving GAO’s oversight of contract modifications and its invoice review processes; (2) Clarifying guidance on subcontracting could reduce GAO’s risk of paying excessive pass-through charges; and (3) Clarifying GAO guidance could help staff follow consistent procurement processes. Read more here.
SBA’s AI Fraud Detection Pilot Didn’t Include Needed Safeguards, OIG Says
Source: NextGov/FCW
The Small Business Administration has been using an artificial intelligence tool to detect fraud in its COVID-19 loan programs, but it did not label the then-pilot as a high-impact use case — a classification that requires federal agencies to meet minimum standards for risk management practices, according to SBA’s Office of Inspector General. The federal agency that supports the growth of U.S. small businesses has been using Palantir software to identify fraud in disbursed pandemic assistance loans. Read more here.
More Than 3 Million People Affected by Military Data Breach
Source: Federal News Network
A breach of the Defense Manpower Data Center’s information system exposed the personal information of more than 3 million people with ties to the U.S. military, a Pentagon official told Federal News Network on Monday. Read more here.
Congress Eyes Slew of AI Security Proposals
Source: Federal News Network
Proposals to secure artificial intelligence are piling up on Capitol Hill, as lawmakers consider various governance mechanisms amid a steady stream of concerning AI security incidents. From AI kill switches to new safety boards, lawmakers in both parties are responding to concerning AI incidents by proposing more federal oversight. Read more here.
AUDITS & INVESTIGATIONS / BUSINESS & TRANSACTIONS / CORPORATE & ORGANIZATIONAL GOVERNANCE / GSA FEDERAL SUPPLY SCHEDULES
Government Accountability Office (GAO) Report: Fraud in Federal Programs: Limited Beneficial Ownership Information Available on Awardees
Source: U.S. Government Accountability Office
On September 30, GAO released a report providing insights from federal, state, and commercial data sources to identify beneficial owners and related fraud risks related to federal awards. GAO found that illicit actors have obscured beneficial ownership to fraudulently obtain hundreds of millions in federal awards, such as contracts, grants, and federal health care programs; while the federal award process requires award recipients to disclose ownership relationships, such as the parent-subsidiary entity relationship, it does not require them to report beneficial ownership information; there is no central repository of beneficial ownership information for businesses that receive federal awards (SAM and FinCEN only provide limited information); and the NDAA for FY 2021 requires GSA to maintain a database that contains beneficial ownership information for federal contractors but has not yet done so because it intended to use FinCEN’s company registry, but those data are now limited. Read more here.
CONFERENCES:
Federal Government Contracting 101: A Roadmap for Commercial Businesses
October 17, 2026
ACRA’s 32nd Annual Conference
Speaker: Timothy “Tim” F. Valley, Jr.
Upcoming Presentations
PM WEBINARS:
Buying and Selling a Business: M&A Processes and Procedures
October 21, 2026
Speaker: Kristen Centre