Government Contractors Alert: New Mandatory Disclosure and Ethics Rules for Government Contractors
Effective December 12, 2008, new rules require contractors to make mandatory disclosures to the government of certain violations of federal criminal laws, violations of the civil False Claims Act and significant overpayments. A knowing failure to make such disclosure is a cause for suspension or debarment.
This mandatory disclosure policy is a "sea change" from historical voluntary disclosure systems familiar to contractors.
In addition, new contracts will be subject to elements of a code of business ethics and conduct awareness, a compliance program and an associated internal control system. Contracts performed outside of the United States are also subject to the same requirements, with contracts for acquisition of a commercial item and small businesses exempt from program requirements but still covered by disclosure rules.
To learn more about these new rules and the implications for your company, download the attached overview by Rod Mateer, director, Deloitte Financial Advisory Services LLP.