As a government contractor, you're likely familiar with the intricacies of the Federal Acquisition Regulation (FAR). Among these, FAR clause 52.209-6, aptly titled "Protecting the Government's Interest When Subcontracting With Contractors Debarred, Suspended, or Proposed for Debarment," stands out as a critical requirement. It essentially mandates that prime contractors like you must take serious steps to avoid working with any entities that are excluded from federal contracting.
Now, in today's ever-evolving regulatory landscape, simply checking SAM.gov isn't enough. Competent contractors and legal teams understand that thorough due diligence now extends to verifying subcontractors against the Office of Foreign Assets Control (OFAC) list as well.
That's where CobbleStone Contract Insight® contract lifecycle management (CLM) software comes into play. Our comprehensive solution is specifically designed to help you effectively manage FAR 52.209-6 compliance by seamlessly integrating robust OFAC and SAM.gov debarred vendor verification directly into your subcontractor management processes.
Let's break down why FAR 52.209-6 is so important. This clause clearly states that prime contractors cannot enter into subcontracts exceeding $35,000 with entities listed in the System for Award Management (SAM) exclusions database as debarred, suspended, or proposed for debarment. The only exception? Explicit written consent from the contracting officer, and that's usually only granted for a truly compelling reason.
But here's the crucial point many are realizing: responsible subcontractor due diligence in today's legal environment demands that you go beyond just a SAM.gov check. You, as contractor managers and legal professionals, must also be acutely aware of the potential risks of doing business with individuals and entities subject to OFAC sanctions.
For those unfamiliar, OFAC, a vital bureau of the U.S. Department of the Treasury, is responsible for administering and enforcing economic and trade sanctions based on U.S. foreign policy and national security objectives. Engaging with OFAC-sanctioned entities can open your organization up to severe legal and financial penalties – something no contractor wants to face.
Therefore, a truly comprehensive approach to subcontractor verification for government contract administrators must include both rigorous SAM.gov exclusion checks and thorough OFAC list screening. This dual-layered approach is the only way to fully safeguard the government's interests and, just as importantly, protect your prime contractor status and reputation.
If you're currently relying on manual processes to verify your subcontractors against both SAM.gov and the OFAC list, you know it's not a walk in the park. It's often a cumbersome, costly, and, frankly, quite error-prone process – especially when you're dealing with a significant number of subcontractors. Here are some of the key challenges that can eat up your time and resources:
Imagine a solution that takes the pain out of subcontractor verification. CobbleStone Contract Insight CLM software offers just that – a powerful platform that streamlines and automates this critical process by seamlessly integrating checks against both the SAM.gov exclusions database and the OFAC sanctions lists.
Here are the key benefits you'll gain for FAR 52.209-6 and overall subcontractor verification:
CobbleStone Contract Insight isn't just about subcontractor verification; it offers a complete and holistic approach to managing the entire lifecycle of your government, GSA, Federal, and DFARS contracts:
Investing in CobbleStone Contract Insight delivers a significant return on investment for government contractors like you by:
CobbleStone Contract Insight consistently earns high rankings and accolades from leading contract lifecycle management (CLM) industry analysts. This recognition underscores our platform's comprehensive functionality, innovative features, user-friendliness, and our proven track record of delivering real value to organizations operating in highly regulated sectors like government contracting. Analysts consistently position CobbleStone as a leader in the CLM space due to our depth of features, scalability to meet your growing needs, and unwavering commitment to your success.
To discover how CobbleStone Contract Insight CLM Software can empower your organization to effectively manage FAR 52.209-6 and all aspects of federal contractor compliance – including our integrated OFAC and SAM.gov debarred vendor verification – and streamline your entire government contract management processes, we encourage you to reach out. Visit our Contact Us page or request a free demo today. Our team of experienced experts is ready to discuss your specific needs and provide you with a personalized demonstration of our leading CLM solution.
By leveraging CobbleStone CLM's advanced features, including that crucial integrated OFAC and SAM.gov verification, you can confidently navigate the complexities of FAR 52.209-6, significantly mitigate risks, and ensure the integrity of your subcontracting practices. Ultimately, this fosters stronger, more compliant, and more reliable relationships with the federal government.
*Legal Disclaimer: This article is not legal advice. The content of this article is for general informational and educational purposes only. The information on this website may not present the most up-to-date legal information. Readers should contact their attorneys for legal advice regarding any particular legal matter.