Tiptoeing Through the Federal Contracting Minefield

摘要

In the wake of Federal Acquisition Regulation (FAR) ethics-compliance program and disclosure requirements, contractors and other construction professionals must proceed with caution. The requirements for ethics educationrnand training as well as internal controls to prevent and detect fraud, waste and abuse are fairly clear and understood within the construction industry. Less clear and often misunderstood are actually how to establish the elements of an effective compliance program and how to meet the FAR's requirements for self-disclosure of "credible evidence" of ethics violations as well as the consequences of noncompliance with these requirements.