Personal conflicts of interest among contractor employees are an increasingly visible and controversial area of U.S. Government contracting, given the U.S. Government’s expanded reliance on contractor personnel. On November 2, 2011, the FAR Council issued a final rule on preventing personal conflicts of interest for contractor employees performing acquisition functions and issued a request for information regarding whether other privately contracted services in addition to acquisition support present sufficient risk to the integrity of the U.S. Government procurement process to warrant additional regulation.

This paper will review the defects in the new rule; will evaluate what lessons can be learned from the new rule to enhance future rules governing the personal conflicts of interest of U.S. Government contractors’ employees; and recommend better integration of U.S. Government compliance regulations to include conflicts of interest rules, protection of proprietary information, and the mandatory disclosure rule to reduce contractor compliance cost and promote implementation efficiencies through integration.