Exploring the Evolving Regulatory Landscape: Supply Chain Security for Service Contractors
by Barron Avery, Justin Weitz, Alex Hastings, Amanda Robinson (Partners) and Sarah-Jane Lorenzo (Associate), Morgan, Lewis & Bockius LLP
The incoming Trump-Vance administration has service contractors preparing for changes in the regulatory environment. While there is considerable speculation about which Biden-Harris administration initiatives may diminish, equally significant are the emerging issues that are expected to remain a priority, such as supply chain security.
Historically, contractors have often viewed supply chain security compliance as a concern mainly for companies that provide products rather than services to the government. However, as the federal government continues to place significant emphasis on safeguarding federal agencies from supply chain attacks, service contractors are increasingly facing heightened scrutiny and compliance expectations in this area.
Recent and upcoming regulations are focused on prohibiting contracts with companies excluded or removed from federal procurement by the Federal Acquisition Security Council (FASC)—a key executive branch interagency council established to investigate potential security risks in the federal supply chain—or those listed on the Department of Defense’s (DoD) Chinese military companies list. These efforts are likely to continue, with potential direct and indirect impacts on service contractors and their suppliers.
Historical Supply Chain Security Requirements
Service contractors have long been subject to certain supply chain security requirements, particularly those introduced during the previous Trump administration. One of the most notable is the obligation to monitor their own supply chains to ensure that no services provided to the government involve covered telecommunications equipment or services. This requirement, implemented by the Federal Acquisition Regulation (FAR), was established under Section 889(a)(1)(B) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, signed into law by President Trump.
Read the entire article in the Winter 2025 edition of Service Contractor magazine.