If You’re Facing Suspension or Debarment, You Need to Know Who the SDO Is—and What They’re Allowed to Do

You’ve just received a Notice of Proposed Debarment or a Suspension Notice. It’s signed by someone you’ve never heard of before—a Suspending and Debarring Official (SDO).

Now you’re wondering: Who is this person? Do they have the final say? Can they really end my government contracting career with one decision?

The answer: Yes—and no.

At National Security Law Firm (NSLF), we help individuals and companies across the country navigate the complex world of federal suspension and debarment. Understanding what an SDO is and how they operate is the first step in protecting your business, reputation, and future eligibility.

This blog breaks it down clearly: who SDOs are, what they can do, and how to effectively engage with them.

What Is an SDO?

An SDO (Suspending and Debarring Official) is the individual within a federal agency who is responsible for making decisions about whether to exclude a person or company from doing business with the U.S. government.

Each agency that awards contracts or financial assistance has one or more designated SDOs. Their authority is grounded in the Federal Acquisition Regulation (FAR Subpart 9.4) and Nonprocurement Common Rule (2 C.F.R. Part 180).

What Does an SDO Actually Do?

An SDO has the power to:

  • Propose a debarment
  • Issue a suspension
  • Review your written response
  • Hold a fact-finding hearing or informal presentation
  • Negotiate administrative agreements
  • Make a final decision on whether you stay eligible—or get debarred

In short, they are judge, jury, and (sometimes) negotiator.

Who Do SDOs Work For?

SDOs work for their respective agencies, such as:

Each agency has slightly different procedures, but the overarching process is governed by federal regulations.

How Are SDOs Different from Prosecutors or Judges?

An SDO is not a criminal prosecutor or a federal judge. Their job isn’t to convict you or fine you. Instead, their role is administrative: to determine whether the federal government should do business with you based on your current responsibility.

They don’t need to prove wrongdoing beyond a reasonable doubt. The standard is much lower—preponderance of the evidence (more likely than not).

That’s why even an allegation—not a conviction—can lead to debarment.

What Does “Present Responsibility” Mean?

This is the core standard SDOs use. Even if there’s past misconduct, you can still stay eligible by proving you are now “presently responsible.”

That usually means:

  • You’ve acknowledged the problem
  • Taken corrective action
  • Implemented compliance measures
  • Hired independent monitors or auditors
  • Cooperated with agency reviews

Hypo example: A small defense contractor receives a Notice of Proposed Debarment after misclassifying some labor categories. Their attorney presents evidence of retraining, new compliance controls, and a third-party audit. The SDO ultimately agrees to an administrative agreement instead of full debarment.

Can You Talk to the SDO? Yes—And You Should

You or your lawyer have the right to:

  • Submit a written response
  • Request an in-person or virtual presentation
  • Offer a compliance plan or agreement

At NSLF, we regularly negotiate directly with SDOs. We know how they think because our team includes former federal prosecutors and government attorneys who’ve worked closely with these decision-makers.

SDOs are not out to destroy careers—they’re trying to protect government interests. A well-prepared response that shows remorse, reform, and compliance often goes a long way.

How Much Does a Debarment Defense Lawyer Cost?

At NSLF, we believe legal defense should be clear and affordable. That’s why we offer flat-fee pricing:

  • $5,000: Written-only response package (review, strategy, submission)
  • $7,500: Hearing representation (if required, most (but not all) cases do not require a hearing) (includes travel)

We also offer legal financing through Pay Later by Affirm, allowing you to break up fees over 3–24 mont

Why Choose NSLF?

When it comes to SDO defense, NSLF is your strategic advantage. We’re the trusted go-to firm for debarment defense across the country—with 4.9-star reviews on Google.

Why clients choose us:

  • Based in Washington, DC, the hub of federal debarment decision-making
  • Attorneys are former government officials, JAG officers, and agency lawyers
  • We represent clients nationwide
  • We hold security clearances, enabling us to handle sensitive matters
  • Our Attorney Review Board meets weekly to analyze complex cases
  • We handle overlapping issues: FOIA, security clearances, federal employment, etc.
  • Founded by disabled veterans with a mission to protect service members and contractors

Our goal is to deliver maximum value and the best possible outcome—every time.

Additional Resources

Looking for more guidance? Our Debarment Defense Practice Page is your go-to starting point.

There, you’ll find a variety of helpful resources covering everything from the most common mistakes that lead to debarment, to the legal strategies that actually work in defending against it. We also share insights on how our attorneys build strong defenses, what steps you can take to improve your chances of success, and how to maximize the outcome of your case.

Whether you’re just learning about the process or actively fighting a proposed debarment, we’ve got you covered.

Don’t Let One Government Official Decide Your Future—Take Action Now

If you’ve received a notice from an SDO, don’t wait. Every day counts. The sooner you respond, the more options you have. NSLF can help you prepare a powerful defense, negotiate directly with the agency, and keep you off the Exclusions List.

Book your free consultation now—no receptionist, no phone tag. You’ll get a direct calendar link to speak with one of our attorneys. Fast. Private. Easy.

👉 Click here to schedule your consultation and let us take it from here.