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Business Crimes Bulletin

July 2009

New Mandatory Disclosure Rule

By Michael G. Scheininger and Jason M. Silverman

Since Dec. 12, 2008, the ability of company counsel to make independent judgments and to advocate on behalf of their clients has been co-opted. That was the effective date of an amendment to the Federal Acquisition Regulation (FAR), which covers almost anyone who contracts to provide products or services to the federal government.

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