Custody of customer assets
In Defense and Government Contracting, custody of customer assets sits at the intersection of federal procurement law and financial accountability obligations enforced by the U.S. Defense Contract Audit Agency and the U.S. Department of Defense Office of Inspector General. The Federal Acquisition Regulation Part 45, governing government property in contractor possession, sets the baseline, but contractors holding sensitive client funds, equipment, or data face layered scrutiny that goes well beyond standard FAR compliance. Gaps in asset segregation and recordkeeping are consistently flagged in DCAA audits as material weaknesses.
Watch
- FAR Part 45 property management system approvals: DCAA audit triggers and timelines
- DoD OIG reports on contractor commingling of government and private assets
- Contractor-held sensitive data classified under CMMC 2.0 Level 2 custody requirements
- Pending updates to DFARS 252.245 on government property loss reporting thresholds
- Prime-to-subcontractor asset transfer documentation under cost-reimbursement contracts
Recent material activity in Defense & Government Contracting
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