On November 13, 2009 the FAR council proposed new regulations about personal conflicts of interest.  If you help a Federal agency plan acquisitions, develop statements of work, evaluate contract proposals, award contracts, administer contracts, terminate contracts, or determine whether costs are reasonable, allocable, and allowable, then you’ll have some work to do.

You’ll be required to screen your employees for personal conflicts of interest, get financial disclosure forms from them, get updates on the disclosures, get non-disclosure agreements, implement controls for non-public government information, and instruct employees of their obligations.  The biggest requirement is to avoid even the appearance of a personal conflicts of interest.

If the contractor discovers a conflict, they’re required to report it to the contracting officer who will decide whether to develop a mitigation plan, provide a waiver, or suspend the contract, terminate the contract for default, or debar the contractor.

Proposed Regulation – FAR Case 2008-025 Preventing Personal Conflicts of Interest for Contractor Employees Performing Acquisition Functions