New FAR Ethics Compliance Program and Disclosure Requirements
Winter 2009

Increased oversight of Government contractors is here. As a result, contractors doing business with the federal government and their subcontractors are burdened with new compliance obligations. Following the passage last year of the Close the Contractor Fraud Loophole Act, the Civilian Agency Acquisition Council and Defense Acquisition Regulations Council jointly issued a final rule amending the FAR effective December 12, 2008. This new rule, entitled Contractor Business Ethics Compliance Program and Disclosure Requirements ―

• requires federal contractors to establish and maintain an awareness and compliance program and specific internal controls to detect and prevent improper conduct;

• requires federal contractors to timely disclose to the Government whenever the contractor has credible evidence of a violation of law; and

• adds as cause for suspension or debarment, knowing failure by a contractor to disclose a violation of law or significant overpayment.

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