OPPORTUNITIES:
Naval Supply Systems Command Seeks Proposals for WEXMAC 2.0 Contract – The Naval Supply Systems Command has started seeking proposals for a potential $10 billion Worldwide Expeditionary Multiple Award Contract, or WEXMAC, 2.0 to enhance U.S. operational readiness. According to the notice posted on SAM.gov Monday, NAVSUP is soliciting proposals from contractors capable of providing critical logistics, services and supplies to support emerging Territorial Integrity of the United States, or TITUS, requirements.
Army Seeks Proposals for FY 2025 EAGLE II Logistics Support Program – The U.S. Army has started soliciting proposals as it plans to award basic ordering agreements, or BOAs, for fiscal year 2025 under the second iteration of a program to acquire logistics support services. According to a solicitation published Tuesday, the Army will accept offers for the FY 2025 Enhanced Army Global Logistics Enterprise II, or EAGLE II, program through July 10. To learn more about the service’s contracting opportunities, modernization imperatives, force structure optimization and more, join the Potomac Officers Club’s 2025 Army Summit on June 18.
USAF RFI: Low Level Continuous Wave Test – Engineering Services.
LOC RFI: Next Generation Donor Management Software.
Army Sources Sought: IO for High Performance Computing – Scientific, Engineering, Analysis, and Outreach Support Services.
CBP RFI: Traveler Processing and Vetting Software (TPVS) 2.0.
GOVCON INSIGHTS:
GAO Reaffirms Agencies’ Discretion to Award Sole-Source SBIR Phase III Contracts (Even to a Successor-in-Interest) – The Small Business Innovation Research program (SBIR) is a successful initiative that increases the participation of small business concerns in federally funded research and development. Awards under Phases I and II of the program are limited to small businesses. Of relevance to this article, federal agencies may award non-competed SBIR Phase III contracts to recipients of prior SBIR awards (and their legal successors-in-interest of any size), as long as any new award somehow “derives from, extends, or completes efforts made under prior funding agreements under the SBIR program.” 15 U.S.C. § 638(e)(4)(C). Phase III awards are not restricted to small businesses.
Two more centralization, cost savings initiatives from GSA – Two new initiatives are accelerating General Services Administration progress toward centralizing the procurement of common goods and services, simplifying acquisition processes and saving money. GSA is taking initial steps to set up an Office of Centralized Acquisition Services by recruiting contracting officers to potentially join the new organization. At the same time, GSA is digging into the value-added reseller (VAR) model to better understand the role of such companies and what it would take for original equipment manufacturers (OEMs) to sell directly to the government.
GSA Expands Transactional Data Reporting for Price Transparency – The General Services Administration (GSA) announced on Monday the expansion of Transactional Data Reporting (TDR) to increase transparency around what the Federal government is buying and how much it is paying for those goods and services. In a June 9 press release, GSA explained that TDR is how the agency gathers data on prices paid for products and services sold through the Multiple Award Schedule (MAS). Vendors report transactional data to give GSA better insights for acquisition decisions and help lower costs for the Federal government. While GSA first launched TDR as a pilot program for certain Special Item Numbers (SINs), the agency said TDR participation will now be mandatory for SIN holders. The TDR expansion will begin with 62 new product and cloud services SINs at the end of June 2025. GSA said it will expand to all SINs beginning in fiscal year (FY) 2026.
Florida Fuel Supplier Charged in Multimillion-Dollar Scheme to Defraud U.S. Department of Defense, other Federal Agencies – A federal grand jury in Miami returned an indictment today charging a Florida business owner with multiple counts of wire fraud, money laundering, and forgery for orchestrating a scheme to defraud the U.S. Department of Defense and other federal agencies by submitting altered and fake invoices to U.S. Navy ships and other vessels through the SEA Card Program, which allows U.S. vessels to purchase critical fuel from suppliers at ports around the world. According to court documents filed in the Southern District of Florida, between August 2022 and January 2024, Jasen Butler, 37, of Jupiter, Florida, the owner of Independent Marine Oil Services LLC, submitted dozens of falsified documents to multiple U.S. warships — including the USS Patriot — demanding and receiving over $5 million dollars in payments for phony expenses that Butler had not incurred. These ships were attempting to purchase fuel in international ports such as Saudi Arabia, Singapore, and Croatia, among others. Butler also concealed his identity from government officials by using a false name and feigning employment by a fictitious fuel division of a different company. As alleged in the indictment, Butler used the millions in fraud proceeds to personally enrich himself and purchase multiple properties, including in Florida and Colorado.
How the Defense Department is approaching procurement reform – The Pentagon is trying many different approaches to speed up and simplify its acquisition programs, hoping to save billions in the process.
Protect Small Business Opportunities: The “Rule of Two” Faces Potential Elimination – The federal government is actively trying to reduce its size and deregulate agencies across the Executive Branch. As noted in a previous Client Alert by Sam Finnerty, the Federal Acquisition Regulation (FAR) has not been exempt from these initiatives. On May 6, 2025, the FAR Council issued its first formal deregulation measure, signaling that any regulations not explicitly codified by statute may be subject to removal from the FAR and the Small Business Administration’s (SBA) regulations. As a result, the “Rule of Two”—a key policy designed to ensure small businesses have a fair opportunity to compete for federal contracts—faces potential elimination due to its lack of statutory foundation.
Sheppard Mullin’s Government Contracts Team Launches Revolutionary FAR Overhaul Tracker – The Federal Acquisition Regulation (FAR), the bedrock of Federal procurement, is undergoing an unprecedented (some would say Revolutionary) overhaul. The Sheppard Mullin Government Contracts Team has created an online resource to help the Federal procurement community stay informed of the proposed changes. On May 2, 2025, the Office of Management and Budget (OMB) launched the “Revolutionary FAR Overhaul” with Memo M-25-25, signaling a bold shift in procurement practices. OMB’s guiding principle prioritizes flexibility by replacing most non-statutory regulations with streamlined “buying guides.” These guides purportedly will emphasize innovative procurement strategies tailored to different acquisition phases and category-specific solutions for common goods and services. Click here to read more.
Trump Issues Executive Order on Cybersecurity Rolling Back Some Prior Policies and Introducing New Ones – Last week, the Trump administration made its priorities clear for the nation’s cybersecurity posture in the form of the newly issued executive order entitled “Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Order 13964 and Executive Order 14114” (the “Order”). The Order, issued on June 6, was accompanied by a fact sheet that explained the intentions behind the Order and included rationales for certain departures from the January 2025 cybersecurity executive order issued by President Biden at the end of his administration, and another earlier Obama-era executive order.
Clarifying the rules around the Small Business Innovation Research program – The Small Business Innovation Research program is one way to bring commercial products into government. It’s relatively fast and simple, as long as you follow the rules. A new bid protest decision could help clarify those rules.
DOJ Releases Promised Guidelines for Investigation and Enforcement Under the FCPA – On Monday June 9, 2025, the Deputy Attorney General Todd Blanche released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” This much anticipated update directly responds to Executive Order 14209, signed by President Trump earlier this year, which temporarily paused Foreign Corrupt Practices Act (FCPA) enforcement. The new Guidelines focus FCPA enforcement going forward on protecting U.S. business interests, furthering the Administration’s efforts to stamp out cartels and transnational criminal organizations, and prioritizing prosecution of individuals rather than corporations. Conduct that can be described as “routine business practices” in foreign countries, under the Guidelines, will not be pursued.
USAID Official and Three Corporate Executives Plead Guilty to Decade-Long Bribery Scheme Involving Over $550 Million in Contracts; Two Companies Admit Criminal Liability for Bribery Scheme and Securities Fraud – Four men, including a government contracting officer for the United States Agency for International Development (USAID) and three owners and presidents of companies, have pleaded guilty for their roles in a decade-long bribery scheme involving at least 14 prime contracts worth over $550 million in U.S. taxpayer dollars.
- Roderick Watson, 57, of Woodstock, Maryland, who worked as a USAID contracting officer, pleaded guilty to bribery of a public official;
- Walter Barnes, 46, of Potomac, Maryland, who was the owner and president of PM Consulting Group LLC doing business as Vistant (Vistant), a certified small business under the U.S. Small Business Administration (SBA) 8(a) contracting program, pleaded guilty to conspiracy to commit bribery of a public official and securities fraud;
- Darryl Britt, 64, of Myakka City, Florida, who was the owner and president of Apprio, Inc. (Apprio), a certified small business under the SBA 8(a) contracting program, pleaded guilty to conspiracy to commit bribery of a public official; and
- Paul Young, 62, of Columbia, Maryland, who was the president of a subcontractor to Vistant and Apprio, pleaded guilty to conspiracy to commit bribery of a public official.
REGULATION UPDATES:
HUBZone Program Updates and Clarifications, and Clarifications to Other Small Business Programs; Correction – The U.S. Small Business Administration (SBA) is correcting a final rule that was published in the Federal Register on December 17, 2024. The rule clarified and improved policies surrounding a comprehensive revision to the HUBZone Program regulations published in 2019, among other changes. This document is making several technical corrections to the final regulations. Effective June 4, 2025.
FREE TRAINING:
Upcoming Government Contract Presentations (from PilieroMazza):
WEBINAR: Managing the Financial Impact of Tariffs on Your Government Contract, June 17, 2025, Jacqueline K. Unger, Ryan Boonstra
WEBINAR: Legal Strategies & Capture Planning, June 20, 2025, Isaias “Cy” Alba, IV
WEBINAR: Avoiding Common Teaming and Subcontracting Pitfalls, June 25, 2025, Jon Williams
WEBINAR: The Buy American Act and Trade Agreements Act: What Government Contractors Need to Know, June 26, 2025, Jacqueline K. Unger, Abigail “Abby” Finan
TRAINING: Navigating the FAR/DFARS: The Most Confusing and Little-Known Clauses, August 13, 2025, Eric Valle, Kristine “Krissy” Crallé
PM WEBINAR: DOJ Uses FCA to Target DEI Policies and Antisemitism: The Impact on Government Contractors, July 10, 2025, Matthew E. Feinberg, Sarah L. Nash
WEBINAR: How Do I Get Paid When They Stop Paying? Strategies for Construction Contractors, August 1, 2025, Jessica A. duHoffmann, Tracey L. Pruiett
TRAINING: Labor Rules & Regulations: Federal Market Compliance, June 25, 2025, Sarah L. Nash
PM WEBINAR: Multijurisdictional Employers, Part 2: 2025 State-by-State Updates on Non-Compete and Non-Solicitation Agreements, July 1, 2025, Sarah L. Nash, Zachary S. Stinson
PM WEBINAR: Multijurisdictional Employers, Part 3: Best Practices for Paid Sick Leave and Family Leave, August 7, 2025, Nichole D. Atallah, Sara N. Strosser