Senators sound alarm on unaddressed conflicts of interest...

Overview

Bipartisan senators are pressing for implementation of the Preventing Organizational Conflicts of Interest in Federal Acquisition Act (Public Law 117-324), which required the FAR (Federal Acquisition Regulation) Council to update the FAR by June 2024 to strengthen how organizational conflicts of interest (OCI) are identified and mitigated. The law, enacted in December 2022, requires contractors to disclose potential conflicts before contract award; however, the FAR Council’s proposed rule remains incomplete nearly two years after the statutory deadline. That regulatory gap means the final disclosure and mitigation requirements are still pending, but when published they will change how federal contractors approach pre-award screening, capture decisions, and compliance documentation. Contractors should treat this as a high-severity, enterprise-level change: update OCI discovery and disclosure workflows now, prepare written mitigation plans, and ensure capture/proposal teams and legal counsel are aligned on pre-award obligations once the final rule is released. Use this Action Kit and Cabrillo Club’s platform to centralize monitoring, rescore opportunities, and automate compliance artifacts. For guidance on secure operations and related compliance areas, see the Secure Operations Guide and related materials such as the CMMC (Cybersecurity Maturity Model Certification) Compliance Guide and the CUI (Controlled Unclassified Information)-Safe CRM Guide.

Immediate Actions (This Week)

[ ] Monitor the FAR Council rulemaking status and subscribe to alerts for Public Law 117-324 / FAR updates.
[ ] Run an immediate inventory of current solicitations and active capture efforts to flag any opportunities where OCI exposure could be material.
[ ] Convene BD, proposals, contracts, and legal for a rapid OCI playbook review: confirm who owns pre-award OCI screening and disclosure decisions.
[ ] Update capture checklists and win/no‑bid gates to require explicit OCI screening prior to pursuing an opportunity.
[ ] Identify any required immediate disclosures under your current contracts and confirm obligations with contracting officers or legal counsel as needed.

Short-Term Actions (30 Days)

[ ] Draft or update a standard Contractor Disclosure Requirements template and an OCI mitigation plan template to use once the final FAR rule is published.
[ ] Train proposal and capture teams on how to identify common OCI scenarios and on the new internal disclosure workflow so pre-award assessments are consistent.

Long-Term Actions (90+ Days)

[ ] Integrate finalized OCI screening and disclosure steps into your formal capture and proposal workflows, including audit-ready records storage and versioning.
[ ] After the FAR Council publishes the final rule, perform a gap assessment of existing policies and contracts, revise policies and supplier agreements, and run tabletop exercises to validate response and mitigation plans.

Compliance Checklist

[ ] Review and align current procedures to FAR Part 9.5 (Organizational Conflicts of Interest) and the Contractor Disclosure Requirements named by Public Law 117-324.
[ ] Maintain documented pre-award OCI screening results and mitigation plans for each opportunity and contract.
[ ] Ensure legal review sign-off on disclosures prior to submission where a potential OCI is identified.
[ ] Update capture decision gates to require OCI documentation as part of bid/no-bid and proposal submission approvals.
[ ] Establish retention and audit controls for disclosure records to support post-award compliance reviews.

Resources

Public Law 117-324 (text) (TBD pending source review)
[FAR rulemaking / FAR Council updates] (TBD pending source review)

Also see internal guidance:

Secure Operations Guide (/insights/secure-operations-guide)
Related guides:
CMMC Compliance Guide (/insights/cmmc-compliance-guide)
CUI-Safe CRM Guide (/insights/cui-safe-crm-guide)

How Cabrillo Club Automates This

Cabrillo Signals War Room — Already detected this event and delivered this briefing within minutes. War Room continuously monitors regulatory changes, FAR Council filings, and policy notices across federal sources, so you get immediate notification when the FAR Council posts proposed or final rules related to Public Law 117-324. Use War Room alerts to trigger your legal and capture teams automatically when the rule advances.
Cabrillo Signals Match Engine — When OCI-related rule changes alter the risk profile of opportunities, Match Engine automatically rescales your opportunity pipeline and updates match scores and keyword relevance. That lets you see, in real time, which pursuits become higher-risk for OCI exposure and which opportunities may require enhanced disclosure or mitigation before award.
Cabrillo Signals Intelligence Hub — Use the Intelligence Hub to track affected NAICS codes, agencies, and contract vehicles tied to this event profile. Create saved searches and alerts so your team is notified when solicitations or amendments appear on SAM.gov (System for Award Management) or agency sites that match the OCI-focused profile, enabling faster pre-award screening and targeted capture efforts.
Proposal Studio (Proposal OS) — Proposal Studio generates compliance matrices and first‑draft technical approaches that include your updated OCI disclosure language and mitigation plans. The system pulls relevant past performance and template language into draft proposals, and its bid/no-bid decision engine factors in event-driven risk adjustments like this FAR update automatically.
Proposal Studio Workflow Tracker — Use the Workflow Tracker’s 9-gate capture workflows to embed OCI review gates, route compliance and legal reviews, track supplier certifications, and produce audit-ready documentation packages. The tracker keeps an auditable trail of who approved OCI disclosures and when, streamlining both internal governance and potential post-award reviews.

Call to action: Explore the War Room alerts and Intelligence Hub saved searches and then enable Proposal Studio templates and Workflow Tracker gates for OCI screening so your team is ready the moment the FAR Council issues the final rule.