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Prohibition on Contracting with Corporations with Felony Conviction or Delinquent Taxes

Client Alert | 1 min read | 12.04.15

On December 4, 2015, the FAR Council issued an interim rule – with an effective date of February 26, 2016 – that would require a corporation responding to any federal solicitation to represent whether it (1) has a felony conviction for a violation under any federal law within the preceding 24 months or (2) has any unpaid federal tax liability that has been assessed and is not being appealed or paid in a timely manner. Consistent with the Consolidated and Further Continuing Appropriation Acts, any affirmative response made by a corporation to either representation would effectively create an automatic exclusion that precludes award of federal contracts, unless the agency's suspension and debarment official has reviewed the matter and determined that further action is not necessary to protect the interests of the government.


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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....

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