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EEOC Announces it will Require both 2017 and 2018 W-2 Data By September 30, 2019 . . . But the Saga Continues

Client Alert | 1 min read | 05.06.19

The government took two significant steps on Friday regarding the battle over the EEO-1 pay data. Most notably, in response to Judge Tanya Chutkan’s recent ruling, the EEOC issued a Rule requiring employers with 100 or more employees and federal contractors with 50 or more employees to file “Component 2” W-2 earnings data for calendar year 2017 by September 30, 2019. This requirement is in addition to the mandate that such employers submit “Component 2” W-2 data for calendar year 2018 by that same date. The EEOC stated that it believes its portal will be open to receive such filings by mid-July 2019. On the same day, the Department of Justice filed a notice of appeal of Judge Chutkan’s ruling, so the fight over the EEO-1 pay data requirements will continue. However, the appeal does not stay Judge Chutkan’s ruling, so employers should prepare to file both 2017 and 2018 data by September 30th and should stay tuned, as this saga continues.

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Client Alert | 3 min read | 08.18.25

FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment

On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines....