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OGE Issues Final Rule On Post-Employment Conflict Of Interest Restrictions

Client Alert | 1 min read | 07.01.08

The Office of Government Ethics (OGE) issued a 42-page final rule (http://www.crowell.com/PDF/Federal-Register_06-25-08.pdf) providing guidance, including examples, on various post-employment restrictions under section 207 of title 18, including the permanent, one-year, and two-year representational bans applicable to former government employees and, relatedly, the companies that hire them. Because some of the key terms in title 207 are also used in other conflict of interest statutes and regulations -- e.g., the procurement integrity compensation ban in title 41 and FAR 3.104, as well as the conflict of interest restriction governing employment discussions between government personnel and the private sector under section 208 -- the OGE rule has broad applicability and relevance.

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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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