The Federal Acquisition Regulation�s mandatory disclosure provisions require contractors to timely disclose �credible evidence that a principal, employee, agent, or subcontractor of the Contractor� has committed either (i) �[a] violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations,� or (ii) �[a] violation of the civil False Claims Act.� (Emphasis added). In theory, this language appears straightforward and easy to follow. In practice, however, it can be difficult to determine whether a violation has occurred and whether the evidence of such violation is �credible.� The fact that neither the FAR councils nor the Courts or Boards