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Déjà Vu: Another FAR Rule On Contractor Codes Of Business Ethics And Conduct

Client Alert | 1 min read | 11.26.07

The Federal Register of November 23 published a final rule (http://www.crowell.com/PDF/FAR-Rule-On-Contractor-Codes_Federal-Register_11-23-07.pdf), effective December 24, which adds new features to the FAR mandating specified contractor standards of conduct (except for commercial item contracts and contracts to be performed entirely outside the United States), for new contracts expected to exceed $5 million (base plus option year value) and performance of 120 days or more (including flow down to subcontractors of the same value and performance duration). The mandated standards of conduct include (i) having a written code of business ethics and conduct; (ii) providing a copy of the code to all employees performing the contract; (iii) promoting compliance with the code; and (iv) except for small businesses, establishing an ongoing business ethics and conduct awareness program and an internal control system which facilitates timely discovery of improper conduct in connection with Government contracts and ensures prompt corrective actions (such program to include periodic reviews of company business practices, a "hotline," internal and/or external audits, and discipline for improper conduct).

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....