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Contractor Compliance Program Requirements Become Mandatory - DOJ Proposal Runs Counter to Public Policy

November 29, 2007 • Crowell & Moring Webinar


On November 23, the FAR Council issued the long-awaited final rule mandating contractor compliance programs for contractors and subcontractors performing covered contracts (72 FR 65873, Nov 23, 2007). This final rule comes on the heels of a request by the Department of Justice to the FAR Council to impose several additional requirements on federal contractors, including a mandatory obligation to disclose criminal conduct to the government and to "fully cooperate" with government auditors and investigators (72 FR 64019, Nov 14, 2007). DOJ’s rule would make the "knowing" failure to disclose a specific ground for suspension and debarment. DOJ’s proposal is not only fraught with practical problems, but is flawed from a public policy standpoint.

Please join Dick Bednar, Angela Styles, and Shauna Alonge from Crowell & Moring’s Government Contracts Group for a discussion of the final and proposed rules and what they may mean for your company.

Webinar Presentation
Audio Recording of Webinar

Related Government Contracts Bullet Points
Nov. 26, 2007 - Contractor Compliance Program Requirements Become Mandatory - DOJ Proposal Runs Counter to Public Policy
Federal Register - 11/23/07 [PDF]

Nov. 14, 2007 - DOJ Would Mandate Contractor Compliance Programs And Self-Reporting
Federal Register - 11/14/07 [PDF]

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