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 | 04.14.26
On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded.
Client Alert | 4 min read | 04.14.26
FedRAMP Solicits Public Comment on Overhaul to Incident Communications Procedures
Client Alert | 5 min read | 04.14.26
Client Alert | 4 min read | 04.14.26
