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ARTICLE · 05 OCTOBER 2010

Government Contracts – Current Compliance Issues

Thompson Coburn LLP
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This section highlights two major issues related to compliance under federal government contracts from the past year. The first is current compliance issues involving corporate compliance programs and organizational conflicts of interest.

United StatesGovernment, Public Sector
Jan Miller
Jan Miller
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This section highlights two major issues related to compliance under federal government contracts from the past year. The first is current compliance issues involving corporate compliance programs and organizational conflicts of interest. The second includes legislative and regulatory issues on the horizon. We also will highlight a few examples of national interest from the courts concerning ethical lapses. (The major topic of the American Recovery and Reinvestment Act of 2009, known as "ARRA" or the "Stimulus Package," is handled separately in Ryan Manger's section.).

I. Current Issues

A. Contractor Business Ethics Compliance and Disclosure

As we noted last year, the major development in ethics and compliance programs became effective on December 12, 2008, called the "Contractor Business Ethics Compliance Program and Disclosure Requirements," (the "FAR Ethics and Compliance Rule" or "Rule"), and with approximately one year of implementation, it remains the

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