On November 12, 2008, the federal government published a new rule that significantly affects the compliance obligations of all companies doing business with the federal government. The new rule expands the scope of contractors who are required to have a code of business ethics and conduct and an internal control system. The rule also mandates, inter alia, disclosure to the government of certain violations of criminal law, violations of the civil False Claims Act, and significant overpayments. The new rule is effective December 12, 2008.

Please see full update for more information.