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TRADE & GEOPOLITICAL RISK

Buy American Act compliance

Buy American Act compliance sits at the center of Trade and Geopolitical Risk right now, with the U.S. Department of Defense and the Federal Acquisition Regulatory Council tightening domestic content thresholds under FAR Part 25 and the January 2022 final rule that raised the domestic content requirement to 60 percent, with a path to 75 percent by 2029. The U.S. Trade Representative holds parallel authority over waiver conditions and reciprocal trade agreement exceptions that directly affect how multinational suppliers qualify components. Compliance teams are actively re-mapping bill-of-materials documentation and vendor certifications against the stepped thresholds before each contract renewal cycle.

Watch

  • FAR Part 25 domestic content threshold stepping to 65 percent in 2024
  • DoD class deviation waivers: which product categories still qualify and for how long
  • USTR reciprocal agreement exceptions that offset BAA requirements for allied-nation suppliers
  • End-product vs. component-level certification disputes surfacing in GAO bid protests

Recent material activity in Trade & Geopolitical Risk

Active monitoring in place across Trade & Geopolitical Risk. Material developments related to buy american act compliance will appear here as they are published.