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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).

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Client Alert | 4 min read | 05.18.26

(Not) All’s Weld That Ends Weld: Duty Evasion Scheme Ends in Historic $549.5M FCA Settlement

The Department of Justice (DOJ) and the cross-agency Trade Fraud Task Force have upped the ante by an order of magnitude in the government’s pursuit of customs fraud. On May 1, 2026—only a few months after setting its previous record-high customs-related False Claims Act (FCA) settlement of $54.4 million with Ceratizit USA, LLC—the DOJ shattered that record with a $549.5 million settlement with Perfectus Aluminum Inc., its subsidiary Perfectus Aluminum Acquisitions LLC, and a set of four affiliated warehousing companies. The Perfectus settlement resolves allegations that the defendants violated the FCA by evading antidumping and countervailing duties (AD/CVD). The settlement resolves three separate qui tam complaints filed by two individual relators and the Aluminum Extruders Council, an international industry association. Defendants were previously criminally convicted on charges related to the same scheme, and those convictions were affirmed by the Ninth Circuit in 2024....