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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 | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...