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All Those Disclosure Requirements -- They Just Keep Coming


The supplemental funding legislation for the wars in Iraq and Afghanistan (Emergency Military Supplemental Appropriations Act (H.R. 2642)) just signed by the President included the much-debated provision requiring disclosure of "violations of Federal criminal law or overpayments in connection with the award or performance of covered contracts or subcontracts," including contracts outside the United States. In addition, the new law mandates public disclosure of the compensation paid to the top five executives of every contractor (including privately held companies) if the contractor earned in the preceding fiscal year more than 80 percent of its revenue and more than $25 million from "Federal awards."

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