It’s been ten years since the Federal Acquisition Regulation (FAR) was amended to require government contractors to have a business ethics and compliance program – that’s right, it’s a requirement in every government contract and in most subcontracts! Aside from being a requirement in every contract and a core component of a small business’ “present responsibility” (i.e. eligibility to be a contractor at all), recent developments have made it essential for small business to address compliance now.
In particular, the Department of Justice has issued guidance as to what it expects from an organization’s ethics and compliance programs, and has reiterated that it will not tolerate companies that lack an effective program. In other words: get caught without one, and that may be the end of your company. See Holland & Knight’s post about the DOJ Guidance. The good news is there has been a lull in new FAR and other regulatory requirements under this Administration, so this is a good time to play some catch up.
But let’s face it, many small businesses are not where they should be, and some others are not even close. So why aren’t small businesses better prepared and how do small businesses move ethics and compliance programs from a perennial back burner issue to the forefront?
Continue reading at: Holland & Knight’s Government Contracts Blog