Law360, New York ( November 4, 2015, 10:43 AM EST) -- This is a challenging time to be a government contractor. On one hand, contractors are obligated to disclose "credible evidence" of certain categories of misconduct in the formation, administration or closeout of their contracts under the Mandatory Disclosure Rule. Contractors are also encouraged to visit their friendly neighborhood Suspending and Debarring Official to discuss misconduct uncovered within their organizations.[1] On the other hand, newly energized suspending and debarring officials are increasingly focused on uncovering as many details as possible about past (often significantly dated) conduct before they make present responsibility decisions. And now, with a pronouncement from the Department of Justice known as the "Yates Memo," contractors are on notice that every misdeed can result in potentially criminal punishment for responsible individuals across the organization....