Having performed multiple independent reviews of company ethics and compliance programs over the years, utilizing the standards developed by both DOJ and DOD, it is always remarkable to find that, even with relatively well-developed programs, there are invariably notable shortcomings. These can lead to a Federal government determination that a company’s program is actually non-compliant with the U.S. Sentencing Guidelines, the 2020 DOJ guidance, and/or the FAR, thereby exposing companies to significant criminal and debarment risk. This client alert shares a few examples from recent reviews conducted by Contractor Integrity Solutions (CIS) of federal contractors that otherwise had long established programs, including a senior Compliance Officer.
