Federal regulations typically require contractor and grantee self-disclosure of ethics or legal violations. That hasn’t been the case for the prohibition on resources going to OFAC-sanctioned individuals and entities (FAR 52.225-13, “Restrictions on Certain Foreign Purchases,” and Mandatory Provision, “Preventing Transactions with, or the Provision of Resources in Support to Sanctioned Groups and Individuals”)

But USAID is closing that gap in a proposed clause/provision requiring reporting of violations to enable the agency to more effectively oversee this requirement. While USAID is asking for comments, the agency will only address comments that explain why the proposed collection would be inappropriate, ineffective, or unacceptable without a change.“  Now is the time to raise your concerns, for example, about how the information will be used and protected, safety and security concerns, timeliness of submission, etc.