Defense contractors are struggling to navigate a new law that bars the Pentagon from contracting with companies that hire lobbyists for Chinese military companies, given the statute's broad definition of lobbying activities and lack of clarity surrounding its implementation.
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The DOD's forthcoming rule will also need to address the possibility that it affects contracts entered into by the DOD between June 30 and whenever the rule is issued, Kenneth J. Nunnenkamp, an international trade partner with Blank Rome LLP, said.
"What happens if [the DOD enters] into a contract at the end of July, and the definition of lobbying activities is written so broadly as to capture something that people didn't anticipate, does that contract become problematic … Does that contract suddenly become covered or captured? … That's anybody's guess until the regulations come out. It's probably not great that they didn't get the regulations written before it went into effect, but we are where we are," Nunnenkamp said.
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"New Chinese Lobbying Law Raises Q's for DOD Contractors," by Madeline Lyskawa was published in Law360 on July 6, 2026.