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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.

Insights

Client Alert | 4 min read | 09.12.25

SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal

On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A....