Department of Defense Issues Final Rule Requiring Contractors to Certify Compliance with Revolving Door Restrictions

On November 18, 2011, the Department of Defense (“DoD”) issued a final rule that requires contractors bidding on solicitations to certify that former DoD officials employed by or receiving compensation from the contractor who are anticipated to work on the contract have complied with their post-employment restrictions under 18 U.S.C. § 207, 41 U.S.C. §§ 2101–2107, and 5 C.F.R. parts 2637 and 2641, including Federal Acquisition Regulation § 3.104–2.  The representation will be required only one time rather than continuously throughout the performance of the contract.  The certification will apply to all solicitations entered on or after November 18, 2011. 

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