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Recent articles on sanctions, export controls, and visitor compliance
Class Deviation 2026-O0025, Revision 3 does not give CMMC Phase 2 a 2027 date. It tells contracting officers to pull third-party assessment language out of live solicitations and contracts, keep NIST SP 800-171 Rev. 2 under DFARS 252.204-7012, and treat Level 1 / Level 2 (Self) as permitted — not cancelled.
A $2.1M NASA/NSF settlement executed the same day thirty universities owed the Department of War a research security audit. The contended failure was not a hidden relationship — it was a disclosed one, reported internally since 2014, that never reached the certification. Why linkage and elapsed time, not screening, decide these cases.
A clean OFAC screening result is a snapshot, not permanent clearance. Why independent schools need a documented, risk-based rescreening process throughout the academic year, and the three questions that decide whether it holds up: who is covered, who reviews a possible match, and what evidence survives.
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