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Privacy for Everyone! New FAR Rule Imposes Mandatory Training Requirements for Employees Handling PII

Client Alert | less than 1 min read | 12.28.16

After years of consideration, DoD, GSA, and NASA have published a final rule requiring contractor employees who handle personally identifiable information (PII) or work with a system of records to complete initial and annual privacy training that addresses specified elements, including the Privacy Act, working with PII, and the contractor’s incident response plan. The final rule – effective January 19, 2017, and applicable to all contracts including those for commercial items and those below the Simplified Acquisition Threshold – also requires contractors to identify each covered employee, maintain records indicating that its employees have completed the requisite training, and to provide these records to contracting officers upon request.

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Client Alert | 3 min read | 04.14.26

DOJ’s False Claims Act Resolution Against IBM Signals Heightened Risk for Federal Contractors with DEI Programs

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....