• The process to get a UEI to do business with the government is changing.
• The definition of entity uniqueness is not changing.

• Phase-out the D-U-N-S® number as the official identifier for doing business with the government.
• Introduce a new UEI, generated in SAM, as the official identifier for doing business with the government.
• Make it easier to request an UEI to do business with the government.
• Transition to a new service provider to validate entity uniqueness.
• Receive continued support from Dun & Bradstreet (D&B) during the transition.
• Retain D-U-N-S ® numbers already assigned to records for historical purposes following the transition.

• The letters 'O' or 'I' will not be used, to avoid confusion with zero and one.
• The first character will not be zero, to avoid cutting off digits that can occur during data imports - for example into spreadsheet programs.
• Nine-digit sequences will not be used in the identifier to avoid conflict with the nine-digit DUNS® number or Taxpayer Identification Number.
• The first five characters will be structured to avoid conflict with the Commercial and Government Entity (CAGE) Code.
• The UEI will not be case sensitive.
• The final character will be a checksum of the first 11 characters. Checksums are used to detect errors within data.
• The UEI will not contain the entity's Electronic Funds Transfer (EFT) Indicator. The EFT Indicator will remain a separate field in SAM.

• Today, entities go to D&B to request their D-U-N-S ® number.
  • Only after their D-U-N-S ® number is assigned, can they go to SAM and register to do business with the government.
• Today, entities must record any changes to their legal business name and physical address with D&B.
  • Only after their D-U-N-S ® record is updated, and the data is available to SAM, can they update their entity registration.
• Today, entities may have to contact two different help desks if they have questions about their UEI. They contact the D&B help desk for issues related to their D-U-N-S ® number or D-U-N-S ® record, and the Federal Service Desk (FSD) for help with their SAM entity registration.
• Starting in December 2020, GSA is making it easier to get an UEI by streamlining the request and ongoing management process. Entities will go to a single place, SAM, to:

• Request their UEI and register their entity to do business with the U.S. Government.
• Make any updates to their legal business name and physical address associated with the UEI.
• Entities will have a single customer support helpdesk for all UEI and entity transition.

• The D-U-N-S ® number is the official identifier for doing business with the government.
• Entities will continue to register in SAM.gov using the D-U-N-S ® number assigned by D&B.
• Entity uniqueness continues to be validated by D&B as part of the D-U-N-S ® number assignment process.
• GSA publishes the technical standard for the new SAM-generated UEI.

• The D-U-N-S ® number remains the official identifier for doing business with the U.S. Government.
• Entities continue to register in SAM using the D-U-N-S ® number assigned by D&B.
• Entity uniqueness continues to be validated by D&B as part of the D-U-N-S ® number assignment process.
• GSA publishes updated technical specifications, which include the new SAM-generated UEI, for interfacing systems.
• GSA develops tools needed to generate UEIs.
• GSA develops an interface to new entity validation service provider to determine entity uniqueness.
• GSA supports robust testing of new interfaces with agency systems.
• GSA communicates upcoming changes to stakeholders, sharing more detail as available.

• The SAM-generated UEI becomes the official identifier for doing business with the U.S. Government.
• Entities request new unique Entity IDs through SAM.gov before starting their entity registration.
• Entity uniqueness is determined by the new entity validation service provider.
• D-U-N-S ® numbers already assigned to records are retained for historical purposes.
• Your registration will automatically be assigned a new UEI which will be displayed in SAM.
• Purpose of registration, core data, assertions, representations & certifications, Points of Contacts, etc. in SAM will not change and no one will be required to re-enter this data.
• D-U-N-S ® assigned to the registration will be retained for search and reference purposes.

Earlier this year, the Department of Justice Criminal Division published new guidance for corporate compliance programs, providing factors for evaluating their effectiveness. Although meant for prosecutors, this guidance offers companies a better understanding of the Department of Justice's views on the design, implementation, and operation of effective compliance programs. For a detailed overview of the new guidance, please click here . 

So, what does this mean for your company? How can you ensure that your corporate compliance program meets the Department of Justice criteria of effectiveness?

To begin, let's consider why a company needs a compliance program in the first place. Most common legal violations in government contracting such as misrepresentation of certification status, conflicts of interest, mishandling of funds, and fraudulent billings stem from unethical beliefs that permeate the company's organizational culture. Ethics are the compass or moral principles that govern an organization's behavior; and in their absence, the organization is at high risk of taking illegal actions. What's worse is that many legal violations can happen quietly, without management realizing what has taken place.  

Unfortunately, the cost of such behaviors to the business can range from lost revenue to loss of reputation, and even prosecution. Additionally, the damage to the human capital of the company can impact morale, productivity, reputation, relationships, future projects, and income.

However, a solid ethics and compliance program can help prevent illegal behaviors and is required in some contracting circumstances. Here are a few suggestions to help you set up an ethics and compliance program in your business.

In the current regulatory climate, having an effective ethics and compliance program has become a prerequisite to doing business. Without it, the company may face harsh penalties if it ever finds itself in trouble. 

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