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Everything You Always Wanted To Know About Government Contracts Compliance In Five Easy Slides. Jonathan S. Aronie June 4, 2013. “ It takes 20 years to build a reputation, and five minutes to ruin it. . . . .” -Warren Buffett. Five High Risk Areas. Country of Origin Rules
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Everything You Always Wanted To Know About Government Contracts Compliance In Five Easy Slides Jonathan S. AronieJune 4, 2013
“It takes 20 years to build a reputation, and five minutes to ruin it. . . . .” -Warren Buffett
Five High Risk Areas • Country of Origin Rules • GSA Schedule Price Reductions Clause • Mandatory Disclosure Rule • Labor Qualifications Requirements • Gifts & Gratuities Rules “A child of five would understand this. Send someone to fetch a child of five.” -Groucho Marx
Five Risks of Non-Compliance • Breach of contract action • Termination • False Claims Act violation • Suspension/debarment • Criminal prosecution “I busted a mirror and got seven years of bad luck, but my lawyer thinks he can get me five.” -Steven Wright
Five Unfortunate Developments • COs are far less willing to be creative • GSA has elevated price over value • Fiscal constraints are stressing Government and industry • Relators (plaintiff whistleblowers) are bolder • DCAA is more aggressive (if that is even possible)
Five Best Practices • Understand the terms of your contracts, and internalize them • Develop an effective compliance program that includes written policies, training, and monitoring • Reward compliance and discipline non-compliance • Keep good records • Demonstrate management commitment to compliance (tone at the top)
Five Rules For Healthy Living • Do not steal. Do not lie. Do not deceive. • Never do anything you wouldn’t want to see on the front page of the NYT. • Turn square corners. • Get it in writing. • Remember: You can’t be justa little pregnant “Every man is a fool for at least five minutes every day; wisdom consists of not exceeding the limit.” -Elbert Hubbard
“At my lemonade stand, I used to give the first glass away free and charge five dollars for the second glass. The refill contained the antidote..” -Emo Phillips Jonathan S. Aronie202.218.0039jaronie@sheppardmullin.com Questions?