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We are bidding overseas work as a subcontractor. This work requires that our employess are sponsored. The prime contractor is requesting that we use a particular company for sponsorship. We have recently been notified that the prime contractor also owns the company that sponsors employees.

Could this potentially be an OCI? Is there any place in the FAR that will help us in determining if an OCI exist?

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Guest Vern Edwards

If you are competing for a subcontract that is to be awarded by a prime contractor, and that prime contractor wants you to obtain sponsorship of your employees from a particular third party that is owned by the prime contractor, then I see no organizational conflict of interest as explained in FAR Subpart 9.5. Please read the regulation. Something else that is improper might be going on, but what you have described is not an organizational conflict of interest.

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