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180. Are payments made under contracts existing prior to the date of enactment of the National Defense Authorization Act (NDAA) statute (December 31, 2011) exempted from the definition of “significant transactions”?


No general exception will be provided for payments arising out of pre-existing contracts. The assessment of whether such payments are “significant” will be done on a case-by-case basis in line with the criteria discussed in FAQ #174.

Date Released
February 14, 2012