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Government Contractors Face New Compliance Obligations and Potential Mandatory Disclosure Requirements

Contributed by: Nixon Peabody LLP
Originally published: January 2008
By: Brian K. French and Jacob B. Pankowski

In the final weeks of 2007, the federal government amended the Federal Acquisition Regulation
(FAR) to impose new compliance obligations on government contractors. Under the new FAR rule, which became effective on December 24, 2007, contractors must adopt written codes of conduct and implement internal compliance control systems. In addition, the government is also considering a further amendment to the FAR, which would subject contractors to mandatory disclosure requirements and compel “full cooperation” with government investigators. The comment period for this proposed rule ends on January 14, 2008.  More....