Proposed Far Rule Would Require Many Federal Contractors And Subcontractors To Adopt Ethics Program
Client Alert | less than 1 min read | 02.16.07
Proposed changes to the FAR 72 Fed. Reg. 7588 (Feb. 16, 2007) (to be codified at 48 C.F.R. subpart 3.10) would require companies receiving a federal prime contract or subcontract in excess of $5 million to (1) adopt a written code of ethics and business conduct; (2) adopt an employee ethics and compliance training program; (3) adopt an internal control system; and (4) display agency Office of Inspector General hotline posters in common work areas where covered contracts are being performed. Contracts performed outside of the United States, whose performance period is less than 120 days, or that are “commercial item” contracts under FAR Part 12, would be exempt.
Insights
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On September 5, 2025, the Federal Trade Commission (“FTC”) withdrew its appeals of decisions issued by Texas and Florida federal district courts, which enjoined the FTC from enforcing a nationwide rule banning almost all noncompete employment agreements. Companies, however, should not read this decision to mean that their noncompete agreements will no longer be subjected to antitrust scrutiny by federal enforcers. In a statement joined by Commissioner Melissa Holyoak, Chairman Andrew Ferguson stressed that the FTC “will continue to enforce the antitrust laws aggressively against noncompete agreements” and warned that “firms in industries plagued by thickets of noncompete agreements will receive [in the coming days] warning letters from me, urging them to consider abandoning those agreements as the Commission prepares investigations and enforcement actions.”
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California’s Climate Disclosure Laws Continue to Roll Forward
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RADV Audits: Implications and Recommendations for Medicare Advantage Organizations
