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New Rule Broadens Definition of Human Trafficking and Implements Compliance Obligations

Client Alert | 1 min read | 01.30.15

On January 29, 2015, the FAR Council issued a final rule amending the FAR to reiterate the current, zero-tolerance policy for trafficking in persons, expanding the definition of human trafficking and imposing new obligations on contractors. Please visit our blog here and here for our analysis of the new rule, which includes numerous requirements applicable to all contractors and requires that, for contracts with any portion having an estimated value of over $500,000 for supplies (other than commercially available, off-the-shelf items) acquired, or services performed, overseas, contractors must develop and maintain compliance plans (including procedures for monitoring subcontractors and agents and preventing them from engaging in human trafficking) and certify compliance with the rule.

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Client Alert | 3 min read | 04.24.24

Digging Deeper: “American Made” Claims From the Tenth Circuit’s Decision in I DIG Texas v. Kerry Creager Diverge from FTC Guidance

On April 12, 2024, the Tenth Circuit issued a decision in I DIG Texas LLC v. Kerry Creager, which analyzed country-of-origin claims in a manner that diverged from the well-established Federal Trade Commission’s “Made in USA” policy....