7 Essential Components of a Standard Employment Verification Template for Federal Contractors

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Basic Company Information Requirements Under FAR 222-54

Federal Acquisition Regulation (FAR) clause 222.54, often called Employment Eligibility Verification, places significant responsibility on federal contractors. This rule requires companies awarded contracts valued over $150,000 to confirm the work eligibility of every employee working on that contract. Contractors need to perform these employment checks within a specific timeframe – generally 90 days after contract award or 30 days upon worker assignment. The core purpose of this verification process is to help prevent the hiring of unauthorized workers and adhere to federal immigration regulations.

While there are exemptions – contracts performed outside the United States or those with a duration under 120 days – most federal contracts and related solicitations must include this clause. It's essential for contractors to retain comprehensive records documenting their verification procedures. These records must be accessible for review when requested by authorities. It's also prudent to include necessary elements within employment verification templates, like employee IDs, associated contract numbers, job titles, and verification dates. This assists with streamlining any potential compliance reviews or audits. Given the continuous adjustments in federal regulations, contractors should prioritize understanding the current rules to ensure they remain in compliance and avoid potential repercussions.

Federal Acquisition Regulation (FAR) 222.54, often referred to as Employment Eligibility Verification, is a crucial aspect of federal contracting. It's a rule that applies to contractors working on contracts exceeding $150,000, specifically those involving service workers. Interestingly, while the primary focus is on confirming employee eligibility, it inadvertently touches upon broader aspects like wages, benefits, and employee conditions.

This rule mandates that the employment eligibility verification clause be incorporated into contracts and solicitations, unless specific exceptions exist, like contracts outside the US or those under 120 days. It necessitates verification within a specific time frame—90 days post-award or 30 days after assignment—and this verification must include a determination of whether individuals are legally permitted to work in the US. This requirement is part of a larger effort to deter the employment of undocumented individuals and to enforce immigration regulations.

It's worth noting that the contractor is responsible for maintaining detailed records of this verification process, which can be requested by government auditors at any time. The format of this verification is also outlined, with essential details like employee ID, contract details, job title, and verification date. Moreover, FAR 222.54 necessitates a robust documentation process, which is crucial for ensuring compliance and enabling easy review during potential audits.

A surprising element is that the term "contractor" is quite expansive, encompassing not just businesses but also non-profits and educational entities engaging in federal contracts. There are likely a greater number of parties that need to understand this rule than we might expect. One could argue that the rule is overreaching in certain ways as well, for instance the concept of "commercially available off-the-shelf" can be highly situation-dependent and isn't always easily defined. It's also important to understand that federal contractors may encounter other specific rules and audit requirements related to their service or industry, meaning they cannot just be satisfied with the most basic level of compliance.

Ultimately, the need to verify employee eligibility isn't just about fulfilling a regulatory mandate. It emphasizes the importance of rigorous internal processes within the human resource domain and can influence a company's operational strategy from top to bottom. This rule necessitates a careful examination of how organizations operate, and its failure to be adhered to can lead to severe penalties, from contract termination and reputational damage, making it clear that these regulatory requirements are not a formality, but rather a critical component of building and maintaining trust and stability in federal contracting.

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Documentation Standards for Employee Identity and Work Authorization

Ensuring compliance with federal contracting rules necessitates strict standards for verifying employee identity and work authorization. Federal contractors are required to confirm the eligibility of every employee working on contracts over $150,000, typically within 90 days of contract award or 30 days after assigning a worker to the project. Employees are obligated to complete the first section of the I-9 form on or before their initial day of work, highlighting the significance of early verification. It's crucial to remember that falsifying information or using fraudulent documents during this process can result in severe penalties, emphasizing the importance of upholding integrity in all interactions.

One key method of establishing work authorization is the Employment Authorization Document (EAD), valid for a specific duration. To obtain an EAD, an individual needs to file the relevant application, Form I-765. These processes, while necessary, can be convoluted. Contractors must strive for clear and consistent documentation procedures throughout their organizations to avoid costly mistakes and potential legal ramifications. While there are exceptions for contracts outside the U.S. or those lasting under 120 days, the majority of federal contracts require these verification procedures. It's clear that adherence to these standards is a cornerstone of responsible federal contracting.

When dealing with federal contracts exceeding $150,000, especially those involving service workers, FAR 222.54 mandates that contractors verify the eligibility of every employee working on the contract. This rule, often called Employment Eligibility Verification, applies not just to large corporations but surprisingly, also to small businesses, educational institutions, and even non-profits. This broad definition can often lead to unintended violations simply because many organizations aren't fully aware of the implications.

Keeping detailed records of this verification process is incredibly important because auditors can request them at any time. Failing to have these records readily available could have serious consequences for the contractor. It's also interesting to note that the way verification is done can differ based on the specific contract and the company's internal structure. This variability can be tricky because it makes consistent compliance across different projects or within departments more challenging.

The deadlines imposed by FAR 222.54– either 90 days after contract award or 30 days from employee assignment – emphasize the urgent need to comply. Not meeting these deadlines not only raises questions about an employee's eligibility but can also throw off project schedules. Also, this verification process adds a more stringent hiring step, which could potentially lengthen the time it takes to vet applicants. If not handled carefully, this might negatively impact a company's reputation when competing for top talent.

This rule also plays nicely with other federal regulations, like the Immigration Reform and Control Act (IRCA), which adds another layer of complexity to compliance. It's essential for contractors to grasp these interconnected regulations so they avoid any accidental violations. One of the trickier aspects is that some terms used in the regulation, like "commercially available off-the-shelf", can be interpreted differently depending on the situation. If auditors take a very strict view, it can lead to unexpected compliance problems.

We're seeing a trend towards using digital record-keeping systems to store these verification documents, which can certainly be efficient. But this shift also requires careful planning to ensure data integrity and easy access when auditors come calling. When dealing with international employees or projects that involve foreign staff, the verification requirements become even more intricate. While some contracts performed outside the US are exempt, navigating different labor laws and regulations across borders can be a real headache.

Beyond fines and penalties, failing to follow employee verification standards can significantly harm a company's reputation. These days, ethical hiring practices and compliance are extremely important to stakeholders. It's crucial for contractors to adjust their procedures to ensure they are aligned with these values. In essence, FAR 222.54 pushes contractors to thoroughly examine their human resources practices. It's not simply about checking a box; adhering to these regulations is vital for fostering trust and maintaining a stable position in federal contracting.

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Mandatory Data Fields for Federal Contract Information Tracking

Federal contractors are obligated to meticulously track contract information, ensuring compliance with government regulations and fostering transparency. This requirement stems from the need for accurate and readily available data, with the Federal Procurement Data System (FPDS) serving as the primary repository for this information. The FPDS is a massive collection of contract data, including information from millions of past contracts, now providing a crucial public resource.

To ensure that essential contract information is collected, tools like the Contract Data Requirements List (CDRL) are used to identify the specific information that must be included in contract bids and agreements. These lists effectively guide contractors in meeting their reporting obligations. Maintaining a robust system for tracking contract milestones is another essential component, with initiation and completion dates for crucial deliverables needing precise record keeping. This is vital for contractors to effectively manage projects and provide updates to stakeholders.

In light of these numerous tracking requirements, adherence to mandatory data fields becomes critical for avoiding complications and repercussions. It's clear that the federal government expects a high level of transparency and accountability from contractors, placing a burden on companies to manage vast quantities of data. Any failures in complying with these requirements could result in substantial penalties, potentially including contract termination or reputational damage. This highlights the importance of rigorous data management practices within organizations working with the federal government.

The concept of "federal contractor" encompasses a broader range of entities than many might initially assume, including non-profit organizations, educational institutions, and even smaller businesses. This highlights the extensive reach of compliance obligations under FAR 222.54, impacting a wider array of organizations than initially apparent.

The 30-day and 90-day timeframes for confirming employee eligibility put pressure on contractors to act swiftly. Missing these deadlines can cause not only compliance issues, but also disruptions to project schedules. It's not just about adhering to rules—it's about managing the timing of various processes.

The requirement that employees complete the first section of the I-9 form before their first day of work underscores the need for early and thorough verification procedures. This aspect of the process is crucial for preventing later complications and ensuring compliance from the outset.

Maintaining comprehensive records of the verification processes is critical, as auditors can request access to them at any point. The lack of these records could trigger negative consequences for contractors, potentially leading to audits failing and even contract termination. It highlights how important documentation can be.

While digital systems for archiving verification documents can be efficient, they also introduce a new set of concerns. It's a challenge for contractors using electronic systems to ensure both data integrity and easy access when auditors need it. These issues need to be addressed before full-scale reliance on these systems.

FAR 222.54 doesn't exist in a vacuum. It intersects with other regulations, like the Immigration Reform and Control Act (IRCA). This interaction introduces a more intricate compliance landscape for federal contractors who must manage a complex web of overlapping rules.

Verification processes can differ significantly based on contract details and how a company is structured. This variation makes it more complex to maintain consistent compliance across various projects or within different departments. The inconsistencies might result in inadvertent violations of the rules simply because compliance efforts are inconsistent.

The phrase "commercially available off-the-shelf" is one that can cause confusion, and this creates compliance problems. It's especially problematic when auditors take a rigid approach to interpreting the rules. We see in other parts of the government that how terms are defined can really matter.

Beyond adhering to the law, contractors also face mounting pressure from various stakeholders to prioritize ethical hiring practices. This push for responsible hiring means that a lack of compliance with verification standards can negatively affect a company's reputation. It’s a matter of public image as much as fulfilling a legal duty.

For federal projects that involve international employees, the verification process becomes more involved. Navigating varying labor laws and immigration policies across borders is a significant burden for contractors with international teams. This international element underscores the more nuanced challenges associated with working in a globally connected world.

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Time Tracking and Employment Duration Verification Methods

Federal contractors operating under contracts exceeding $150,000 must diligently track employee time and verify their employment durations to comply with federal regulations. These practices not only ensure adherence to legal requirements but also strengthen overall workforce management by aligning employment verification with eligibility standards. Time tracking systems offer a mechanism to accurately capture when employees work on federal contracts, crucial for demonstrating compliance. However, this focus on verification and tracking is not just about avoiding penalties. The continuous evolution of federal contracting regulations means that keeping track of employee work duration and verifying employment eligibility is essential to avoiding disruptions and ensuring a smooth operational flow. This task is made more complex because of how federal contracting rules intersect with other government regulations. Moreover, stakeholders within the federal government now emphasize a strong link between careful and consistent employment verification processes and the need to build trust and provide timely access to verifiable employment information. Ultimately, implementing robust time tracking and verification procedures is crucial for both operational efficiency and risk mitigation within the world of federal contracting.

Federal contractors, as we've discussed, have a legal responsibility to verify the eligibility of their employees under FAR 222.54. This usually involves confirming if an employee is legally allowed to work in the US, but it also involves tracking time worked and confirming employment duration. There are a few things that stand out about these methods.

First, the roots of time tracking are surprisingly old. The need to keep tabs on worker hours goes back to the Industrial Revolution, when factory owners wanted to see how productive workers were and control their labor costs. That might seem a bit obvious, but it shows us that keeping track of hours has always been a way to manage work.

Secondly, technology has revolutionized time tracking. We now have programs that automate the process, leading to fewer human errors. Some research suggests that these automatic systems can decrease mistakes by as much as 50%, making it far easier to get the employment duration verification accurate and keep compliance records in order.

Interestingly, there are now biometrics used in some companies. This might sound futuristic, but it's becoming more common. Systems that read fingerprints or use facial recognition are helping to reduce fraud, specifically where an employee clocks in for a coworker (buddy punching), which can be cut down by up to 90% with these new tools.

Of course, employment duration verification is intertwined with labor laws, and those can be confusing. It depends on the laws of the state or even country. Some places require companies to record the exact number of hours, while others are a bit more flexible. These differences make it important for contractors to stay on top of the various regulations and avoid mistakes.

There's also a cognitive dissonance with time tracking. Some studies suggest that employees actually underestimate how long they've worked, leading to discrepancies in the official record of employment. It's not intentional, but it has the potential to throw off payroll and accounting processes.

One unexpected effect is that time tracking might make people more aware of how productive they are. Researchers believe this can boost output as people become more mindful of how they use their time. This is a positive feedback loop—keep tabs on work, understand better how time is used, which then can improve the work.

We're also seeing tighter connections between project management tools and time tracking. This makes it much easier to assess how profitable a project is and where resources are being used.

Speaking of the consequences of not verifying employment duration properly, a study shows that breaking the rules can cost a mid-sized company about $50,000 in fines and legal fees. This underlines the importance of doing things right, as it's not just a matter of checking a box—it can be very expensive if it's handled incorrectly.

Some companies are even starting to use time tracking data as part of employee performance evaluations, tying things like attendance and completion rates to bonus or promotion structures.

Looking forward, with remote work becoming more and more common, there's likely to be more emphasis on new approaches to time tracking. Activity monitoring software, that analyzes what a worker is doing while on the computer, is getting more attention. This raises some concerns about employee privacy, especially with where the data is stored and who has access to it. This means the methods we use to verify employment in the future may have a different emphasis than what we see today.

These examples illustrate that the simple act of keeping track of time is more complex than it appears on the surface, requiring companies to be thoughtful in how they approach the process and ensure they are doing things the right way.

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Compliance Requirements for Subcontractor Employment Records

When federal contracts exceed $150,000, the primary contractor takes on responsibility for the employment records of their subcontractors. This means keeping detailed records of their employees for two years, which is a key aspect of complying with the Office of Federal Contract Compliance Programs (OFCCP). The OFCCP, which enforces rules designed to prevent workplace discrimination, requires detailed records as a way to monitor compliance. This can include information on a worker's start and end dates, job duties, and pay. Federal regulations mandate that records are well-kept and that they can be presented for review if an audit is conducted.

Subcontractors working on projects exceeding $5 million and lasting more than 120 days must also comply with disclosure obligations as part of the contract terms. Failure to comply can put both the subcontractor and the prime contractor at risk. While it can be tempting for the prime contractor to view this aspect as a task for the subcontractor, it's important for them to understand that if a problem arises, both companies can face issues. The federal government makes it clear that contractors must take an active role in verifying compliance. There are updates to the guidelines on how these things are audited that should be reviewed regularly. This all points to the need for strong, consistent compliance throughout the chain of employment relationships to prevent issues and build a positive working relationship with the federal government. The rules can seem complex, but a lack of attention to these record-keeping requirements can lead to legal difficulties and significant reputational damage, so it is important that contractors are careful about how they maintain these records and address issues when they arise.

Federal subcontractors, much like their primary contractor counterparts, are surprisingly bound by FAR 222.54, meaning they also must confirm the eligibility of their workers on federal contracts. This broadens the net of compliance beyond the typical large companies and into smaller operations, potentially including smaller entities who might not even realize they are subject to the rule.

Many contractors, whether they are large organizations or small subcontractors, may not realize that failing to keep accurate records of the verification processes isn't just a compliance issue—it could mean a contract getting terminated. And each contract failure can lead to some really hefty penalties and legal fees, often over $50,000. It seems pretty easy to get caught up in doing the core part of the work, but it can be easy to miss the detailed compliance requirements in the meantime.

The nature of these employment verification procedures could lead to audits that extend far beyond the initial compliance area, like wage laws and general labor practices. What might appear as a minor error in one area can lead to bigger problems that the contractor wasn't expecting. It seems like a small error can cause a ripple effect of other issues that might cause more severe problems later on.

To manage and streamline all the compliance efforts related to these verification processes, companies are using more software solutions. However, these systems present some challenges in relation to the integrity of the information and how that information is accessed if there is an audit. Given how important it is to maintain compliance, contractors need to make sure their staff have the necessary training to operate the system and make sure the data is reliable.

It is interesting that the newer biometric tools can supposedly reduce time theft through "buddy punching" by up to 90%. It appears the value in this new technology isn't only about meeting the letter of the law but can be more about how employees and teams manage themselves and track their own time in a new way. One might wonder if this might open up more opportunities in terms of productivity and workflow.

Research has shown that when people track their time, it seems they become more mindful of how they spend their workdays, often improving productivity. This is quite fascinating—it could change how companies design and manage their work environments. It might be interesting to see if the way people perceive time and work could be leveraged for better operational designs or planning.

Not meeting the deadlines for verification, especially the 30 and 90-day timeframes, can cause major disruptions in the timeline of the project. It's a good reminder that being compliant isn't just about checking a box—it's essential for projects to stay on track. There can be a surprising link between these kinds of compliance requirements and the everyday execution of the work itself.

The definition of "employee" under FAR 222.54 is a bit broader than what people might typically think. It might encompass people that contractors consider independent contractors, which can lead to some issues, particularly if a smaller organization isn't sure of the specific implications of the rule. It's probably a good idea to err on the side of caution in this case.

Compliance tools and strategies need to be dynamic to keep up with the changing landscape of federal contracting regulations. If the tools used for compliance are out of date, it's easy to make errors or miss something crucial, especially given the fairly steep penalties. It is likely a good idea to set aside some time to revisit these strategies in a regular way.

When we are talking about employment verification, it is important to consider both the federal requirements and the local or state regulations that might also apply. There might be some discrepancies between federal and state rules, and it's crucial for companies to have a thorough understanding of what applies in their region to avoid trouble. The more complex a project becomes, the more complicated compliance efforts seem to be.

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Electronic Verification System Integration Protocols

"Electronic Verification System Integration Protocols" essentially detail how federal contractors can incorporate electronic tools, like EVerify, into their existing employment verification processes. These protocols aim to improve efficiency and compliance with federal regulations, such as the Immigration Reform and Control Act (IRCA) and Executive Order 12989, which mandate electronic verification for many federal contracts. EVerify, being a web-based system, allows contractors to quickly compare information from the I-9 form with databases maintained by the Social Security Administration and Department of Homeland Security, providing a faster method for verifying an individual's right to work in the United States.

This is becoming more critical as the government increasingly expects federal contractors to use EVerify, specifically for contracts above $150,000. The core benefit of using these systems is accurate record keeping and avoiding potential fines and other penalties, especially since government oversight in this area is expected to remain a significant factor in federal contracting. While the use of these protocols might appear straightforward, the integration of more sophisticated technology, like automated background checks or advanced identity verification solutions, introduces the need for contractors to remain vigilant about the reliability of the data produced and the capacity to meet audit requirements. It’s not enough to simply implement a digital system; it’s critical to have a plan for managing data integrity and ensuring quick access to information when necessary. This means that simply using EVerify or some other software won’t magically guarantee compliance, and contractors must be aware of the continuing responsibility to safeguard the data produced by these programs in a way that is easy to audit.

Integrating electronic verification systems into employment practices, often referred to as Electronic Verification System Integration Protocols (EVSIPs), offers the potential to significantly streamline the process. Some industry analysis indicates that using these systems can shorten verification times by up to 40%, which can lead to a more efficient use of human resources and potentially higher productivity.

However, it's intriguing to note that many federal contractors still rely on manual systems, despite the advantages of automation. This reliance on older methods introduces the risk of human error, missing records, and potential discrepancies that could lead to violations of federal requirements.

Another interesting aspect of this topic is the concept of "interoperability" within EVSIPs. The goal isn't just to connect different systems, but to ensure that information moves seamlessly between them while maintaining security and data integrity. Unfortunately, a common challenge for companies integrating these systems is creating a consistent flow of data. This often leads to data being isolated in different systems, which can hinder compliance efforts.

Some systems are being designed with artificial intelligence (AI) incorporated into them. This AI can be useful in identifying patterns in verification requests that could be fraudulent or deceptive. This feature allows compliance teams to be more proactive in recognizing risks, potentially reducing the number of instances where unauthorized individuals are hired.

It's also noteworthy that EVSIPs aren't just limited to government contracting. They can be applied to a broad range of industries, including healthcare and construction. This flexibility is indicative of the potential utility of these electronic verification methods for a variety of employment environments.

The difference between manual and automated methods is pretty stark in the area of error rates. Manual verification systems can have error rates of up to 25%, while EVSIPs are reported to have error rates below 5%. This vast difference underlines the importance of transitioning towards automated verification for better accuracy.

One point often overlooked is the need for proper training on how to use the electronic verification tools. Without proper training, employees might use inefficient and non-standard approaches, which can undercut the whole purpose of the system.

A potentially beneficial side effect of EVSIPs is the impact they can have on the way companies keep records. The inherent structure of electronic systems naturally lends itself to a more organized and consistent approach to documentation, which is valuable during audits and reviews.

There is also some evidence that EVSIPs can improve the morale of employees. This is possibly because administrative tasks are reduced, and there's less risk of disruptions due to compliance-related issues, which can impact both project work and overall job security.

Finally, the shift toward remote work has increased the importance of EVSIPs. Traditional verification practices struggle to function in a distributed work model, making it necessary to develop robust electronic integration protocols for managing employment verification in a modern context.

This area of research continues to be fascinating, with new technologies and methodologies emerging regularly. As the federal government's standards and expectations evolve, so too will the need for effective and adaptive EVSIPs.

7 Essential Components of a Standard Employment Verification Template for Federal Contractors - Records Retention and Documentation Storage Guidelines

Federal contractors are obligated to follow specific "Records Retention and Documentation Storage Guidelines" to comply with various federal and state regulations, particularly for contracts over $150,000. These guidelines, outlined in parts of the Code of Federal Regulations, mandate the retention of specific employment records for set periods. For instance, documentation related to affirmative action plans must be kept for at least two years. Similarly, records concerning employment verification, such as I-9 forms, need to be saved to demonstrate compliance, especially during audits. It's worth noting that the rules might vary slightly for contractors with smaller employee counts or contracts with lower values. Maintaining these records isn't just a matter of paperwork; it's a critical aspect of demonstrating that a contractor follows the rules. Auditing these practices regularly is essential to ensure ongoing compliance. However, it's important to remember that government regulations change, so it's crucial for federal contractors to remain aware of any updates to these guidelines. Failure to adapt to changes could result in penalties and, at times, potentially negative repercussions on their ability to continue receiving federal contracts.

Federal regulations, specifically within the Code of Federal Regulations (CFR) Titles 5 and 36, guide the retention of employment and personnel records for government contractors. These rules are overseen by entities like the Office of Personnel Management (OPM) and the Office of Federal Contract Compliance Programs (OFCCP). The government mandates keeping employment records, such as those related to affirmative action plans (AAP), for at least two years. This time period often extends from the end of the fiscal year associated with contract spending.

Interestingly, for involuntarily terminated employees, records need to be retained for a minimum of two years from the date of termination, indicating a need to manage records differently based on employment status. This isn't just for a specific set of contracts either - all employee records, including the ever-important I-9 forms, have specific retention requirements to comply with federal and state regulations.

A constant tension exists within this environment. The need to maintain consistent, accurate records for audits puts a pressure on contractors that isn't typically seen in the private sector. Auditors can unexpectedly require access to the records, which highlights a blindspot in many organizations' record-keeping processes. There is an important and surprising consequence related to the verification process. If any aspect of the record is falsified or inaccurate, the contractor faces potential legal action or severe penalties. This underscores how essential the accuracy of these records is.

Adopting digital record keeping has many upsides, such as improved efficiency and reduced errors. However, the transition to these new technologies poses new challenges, such as managing data flow and protecting sensitive information. Contractors must carefully plan the transition to digital systems, considering the data security implications.

It's also somewhat surprising how many smaller contractors may not be aware of the implications of FAR 222.54, potentially leading to significant issues, including large fines or even losing the ability to bid on federal contracts. This points to a gap in knowledge and the need for better outreach to these organizations to avoid unintentional non-compliance.

Using electronic verification systems, such as E-Verify, can improve efficiency and reduce errors. Studies show that electronic verification reduces errors by up to 20%, which might make it appealing for organizations to move towards more technology-based record keeping. These tools can also accelerate the verification process, potentially cutting down verification times by up to 40%, which can benefit project schedules and human resources management.

However, the use of electronic systems raises concerns about data security and privacy. Contractors need to be aware of their obligation to protect sensitive employee information from data breaches. Moreover, the term "employee" has a rather broad definition in these regulations, including things like independent contractors. This broader definition means companies must be diligent in interpreting their obligations as it relates to their workers.

New audit methodologies are emerging that make real-time compliance reviews more common. This suggests that contractors can't just treat compliance as a periodic task; it's becoming increasingly important for organizations to be proactively compliant.

There's a persistent need for organizations to continuously adapt and update their record keeping strategies. These rules, as with most regulations, are dynamic, with updates and changes common in the environment of federal contracting. Organizations must be diligent in understanding the evolving regulatory landscape to mitigate compliance risks.