On November 7, 2025, the U.S. Department of Defense announced a comprehensive overhaul of its procurement strategy named the “Acquisition Transformation Strategy” (ATS). The ATS envisions a wartime-oriented process that aims to prioritize rapid fielding to get equipment into the hands of warfighters, industrial-base expansion, and tighter coupling of requirements, resourcing, and acquisition execution. The accompanying directives signal a consequential restructuring of U.S. defense acquisition, requirements, and security cooperation processes as the Department aims to disestablish legacy joint requirements governance in favor of an integrated, budget-aligned model that is focused on speed, accountability, and mission outcomes. The new “Warfighting Acquisition System” will replace the existing “Joint Capabilities Integration and Development System,” creating both new opportunities and risks for federal contractors as they navigate shifting compliance expectations and material risk exposures in all aspects of the defense acquisitions process, including budget overruns, timely performance, and exportability of next-generation platforms. 

Winston’s Financial Services Industry Group is closely monitoring debanking regulations and advising global financial institutions on customer onboarding and due diligence.

In this alert, Jack Knight, Carl Fornaris, Patrick Doerr, and Arman Aboutorabi examine Senator Thom Tillis’s (R-NC) proposed Ensuring Fair Access to Banking Act. Although the bill is nominally designed to “limit the circumstances under which a Federal financial regulator may require a financial institution to terminate a specific account,” it in fact proposes much more.

Senator Thom Tillis’s discussion draft of the Ensuring Fair Access to Banking Act would create a single federal “fair access” standard prohibiting “debanking” except in defined circumstances, grant enforcement authority to federal and state regulators, and preempt state fair-access laws. These changes could impact account-opening, maintenance, and exit decisions and increase litigation exposure. Read the full alert for key implications, open questions, and practical steps institutions can take now.