New Government Contractor Rules on Personal Conflicts of Interest and Revolving Door Restrictions

Implementing Internal Controls to Comply With FAR PCI Requirements and DoD Post-Employment Restrictions

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Wednesday, February 1, 2012

Recorded event now available

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Course Materials

This CLE course will provide counsel with a briefing on the new federal contractor rules on personal conflicts of interest and revolving door restrictions. The panel will provide best practices for implementing internal control systems, training employees and managing any required disclosures.


The new Federal Acquisition Regulation (FAR) provision on personal conflicts of interest for contractor employees took effect Dec. 2, 2011. The rule requires federal contractors who perform acquisition-related functions to screen for and prevent personal conflicts of interest among their covered employees.

The Department of Defense (DoD) also recently finalized a rule that requires defense contractors to certify that former DoD employees working for the contractor are in compliance with federal revolving door laws.

Counsel to contractors must have a detailed understanding of the FAR and DoD requirements to ensure that they are in full compliance with the mandates. Contractors should implement internal controls outlining how they will identify, prevent and report personal conflicts of interest.

Listen as our authoritative panel of government contract attorneys discusses the recently implemented FAR and DoD rules on personal conflicts of interest and revolving door restrictions. The panel will explain steps that contractors and their counsel should take to implement internal control systems, train employees and manage required disclosures.



  1. Overview of new compliance requirements
    1. FAR final rule on personal conflicts of interest
    2. Department of Defense revolving door rule
  2. Best practices for complying with the requirements
    1. Determining who is covered by rule
    2. Implementing internal controls
    3. Training employees
    4. Mandatory disclosures
    5. Impact on subcontractors
    6. Bid protest implications
    7. False Claim Act implications


The panel will review these and other key questions:

  • What new requirements do the FAR and DoD rules impose on federal government contractors?
  • What strategies are effective for establishing internal controls to ensure and monitor compliance with the FAR and DoD requirements?
  • What factors should contractors take into consideration when determining how to comply with mandatory disclosure requirements when improper conduct has occurred?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Robert A. Burton
Robert A. Burton


He is a nationally-recognized federal procurement attorney, who focuses his practice on assisting government...  |  Read More

Keith Szeliga
Keith Szeliga

Sheppard Mullin Richter & Hampton

He counsels clients regarding the full spectrum of regulations applicable to federal, state and local government...  |  Read More

Shauna E. Alonge
Shauna E. Alonge

Crowell & Moring

Her law practice emphasizes procurement ethics, defense of criminal and civil fraud matters, including qui tam...  |  Read More

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