Déjà Vu: Another FAR Rule On Contractor Codes Of Business Ethics And Conduct
Client Alert | 1 min read | 11.26.07
The Federal Register of November 23 published a final rule (http://www.crowell.com/PDF/FAR-Rule-On-Contractor-Codes_Federal-Register_11-23-07.pdf), effective December 24, which adds new features to the FAR mandating specified contractor standards of conduct (except for commercial item contracts and contracts to be performed entirely outside the United States), for new contracts expected to exceed $5 million (base plus option year value) and performance of 120 days or more (including flow down to subcontractors of the same value and performance duration). The mandated standards of conduct include (i) having a written code of business ethics and conduct; (ii) providing a copy of the code to all employees performing the contract; (iii) promoting compliance with the code; and (iv) except for small businesses, establishing an ongoing business ethics and conduct awareness program and an internal control system which facilitates timely discovery of improper conduct in connection with Government contracts and ensures prompt corrective actions (such program to include periodic reviews of company business practices, a "hotline," internal and/or external audits, and discipline for improper conduct).
Insights
Client Alert | 4 min read | 04.09.26
DOJ Establishes National Fraud Enforcement Division
On April 7, 2026, Acting Attorney General Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (NFED) within the U.S. Department of Justice (DOJ). This new division will be dedicated to the centralized, coordinated investigation and prosecution of fraud against taxpayer dollars and taxpayer-funded programs. AAG Blanche acknowledged that, while DOJ has a “storied history of combatting fraud,” DOJ has “never adopted a comprehensive and coordinated approach to investigating and prosecuting fraud against taxpayer dollars and tax-payer funded programs.” The NFED was created to close that gap with its core mission being to “zealously investigate and prosecute those who steal or fraudulently misuse taxpayer dollars.”
Client Alert | 2 min read | 04.09.26
OMB Issues New Policy on Federal IT Transparency and Acquisition Oversight
Client Alert | 3 min read | 04.09.26
Preserve It or Lose It: A Missing Jury Instruction Costs Columbia University $94M in Damages
Client Alert | 5 min read | 04.09.26
U.S. State Privacy Enforcement: Key Priorities and Practical Guidance From State Regulators
