Remove Ethics Remove Evaluation Remove Internal Control
article thumbnail

New OCI Rule Contains Big Changes

SmallGovCon

It will also change the title of the part from Improper Business Practices and Personal Conflicts of Interest to Business Ethics and Conflicts of Interest. ” Use of “structural or behavioral barriers, internal controls, or both.” to a new subpart in FAR part 3.

article thumbnail

Criminal Enforcement Considerations for Gov’t Contractors

Government Contracts Legal Forum

Government contractors should evaluate whether to voluntarily disclose criminal wrongdoing once detected and throughout any internal investigation as facts are developed. The DOJ’s charging and resolution determinations will include an intense evaluation of the company’s compliance program. 11] This is consistent with the U.S.