Scope of Proposed Rule on Self-Reporting is Expanded and Would Also Require Self-Reporting of FCA Violations and Contract Overpayments
Client Alert | 1 min read | 05.16.08
The FAR Secretariat today published for public comment an amendment to the proposed rule (73 FR 28407, May 16, 2008) that was previously published at the request of DOJ, to require contractors to have a code of ethics and business conduct and to notify the agency’s Office of Inspector General and the Contracting Officer whenever there is a “reasonable” basis to believe there has been a violation of federal criminal law in connection with a federal contract or subcontract. The amended proposed rule no longer exempts commercial item contracts and contracts that are performed outside the United States and, again at the request of DOJ, adds a requirement that contractors also report violations of the civil False Claims Act as well as contract overpayments, with knowing failures to report such violations being an additional cause for debarment or suspension.
Insights
Client Alert | 4 min read | 09.12.25
SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal
On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.
Client Alert | 6 min read | 09.11.25
U.S. Department of Commerce Partially Relaxes Export Controls on Syria
Client Alert | 9 min read | 09.11.25
Client Alert | 1 min read | 09.10.25
