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OCI Mitigation Doesn't Go Far Enough


In Greenleaf Constr. Co. (Jan. 17, 2006,, GAO found an unmitigated organizational conflict of interest because the owner of the awardee was to receive a stream of payments from another contractor that the awardee would be overseeing and evaluating and whose economic well-being the awardee therefore could significantly affect. The owner of the awardee had been required by the agency to sell the other contractor in order to avoid having an OCI interest in the profits of that other contractor, but GAO found that the interest of the awardee's owner in ensuring that the other contractor would be able to continue making the payments to him might impair the awardee's objectivity in performing its contract evaluation duties.

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Thomas P. Humphrey
Partner – Washington, D.C.
Phone: +1 202.624.2633