On December 24, 2007, significant amendments to the Federal Acquisition Regulation (“FAR”), establishing new ethics requirements for government contractors and subcontractors. Contracting with any federal agency requires establishment of a “Contractor Code of Business Ethics and Conduct.” Government contractors must establish a written ethics and compliance program within 90 days after the contract award. A contractor will have a limited period of time by which to establish an ethics code and internal ethics compliance program – it must consider establishing these programs in advance to ensure compliance with the newly amended FAR.

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