Arnold & Porter·GOVERNMENT CONTRACTS / DEFENSE

FY2025 NDAA Bars DOD Contracts Over Chinese Military Lobbying Ties

Defense contractors and their subcontractors must act because the FY2025 NDAA imposes new contracting prohibitions for entities tied to firms lobbying for listed Chinese military companies, creating material compliance and revenue risk.

The FY2025 National Defense Authorization Act includes a provision barring the Department of Defense from contracting with companies that subcontract with firms conducting lobbying activities for entities on the DOD’s list of Chinese military companies operating in the U.S. This adds a layered compliance requirement for defense contractors, who must now vet not only direct subcontractors but also the lobbying activities of those subcontractors’ partners to avoid losing DOD contract eligibility. Contractors should immediately review their subcontractor relationships and lobbying service vendor agreements to identify and mitigate ties to listed Chinese military companies, and update their compliance protocols as needed.

government-contractsndaachinese-military-companiesdefense-contractor-compliance
Read the original firm alert →Wednesday, July 8, 2026

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