Corporate Compliance Insights – When USAID imposed a funding freeze, contractors faced an impossible situation under FAR and AIDAR requirements: They were prohibited from incurring costs without funding but still required to maintain operational readiness unless formally issued stop-work orders. Contracts and compliance professional Oksana Zolotova explores how the crisis became a governance stress test, demonstrating that many organizations lacked robust termination procedures, tested contingency budgets, or established protocols, forcing local offices to navigate conflicting instructions while attempting to reconcile halted disbursements with ongoing contractual obligations.

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