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
Client Alert | 8 min read | 10.01.25
On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.
Client Alert | 2 min read | 10.01.25
CPSC Shutdown Plan: Continue Enforcement, Pause Public Engagement and Civil Penalties
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CARB Issues Preliminary List of Entities Covered by California Climate Disclosure Laws
