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Are You Ready to Track Your Empolyees' Investments?by Julie M. Nichols,Esq.

As if managing the security clearance process, organizational conflicts of interest, post-government employment conflicts, corporate and agency non-disclosure agreements, and all other contract requirements wasn’t enough; contractors, big and small, get ready to be on the hook for one more – Personal Conflicts of Interest.  Yes, for covered contracts you now will have to track your employees’ personal actions resulting from their work on government contracts performing or supporting “acquisition-related” work and report any violations to the Contracting Officer (CO).  Late last year, DOD, GSA, and NASA issued a final rule designed to prevent personal conflicts of interests for contractor employees performing acquisition functions for government agencies.  The new requirement will be in contracts over the simplified acquisition threshold.  The new rule is now located in the new FAR Subpart 3.11, and look for FAR clause 52.203-16 coming to a government contract near you! ...continue reading.