President Biden Signs Bipartisan Legislation Requiring Agencies to Refer Potential Human Trafficking Matters for Suspension/Debarment Consideration
Client Alert | 1 min read | 11.07.22
On October 17, 2022, President Biden signed the End Human Trafficking in Government Contracts Act of 2022 (“the Act”) into law, amending the 2013 National Defense Authorization Act (“2013 NDAA”) to require U.S. government agency heads to refer any suspected instances of human trafficking to the agency’s suspension and debarment official (“SDO”) for consideration and disposition.
In March 2012, both the House of Representatives and the Senate introduced the End Trafficking in Government Contracting Act of 2012, which Congress eventually passed as part of the 2013 NDAA. The goal of this law was to strengthen anti-human trafficking compliance efforts in federal contracts. However, in recent years, the Government Accountability Office and the Department of Defense Inspector General have released reports finding that human trafficking still persisted among a number of U.S. government contractors.
In addition to requiring agency heads to report suspected instances of human trafficking to SDOs, the Act also requires the director of the Office of Management and Budget to submit a report to Congress on implementation of the provisions within 90 days of the Act’s enactment.
Given this heightened scrutiny, contractors should review the relevant rules, including the requirement to have an anti-human trafficking compliance plan for contracts exceeding $550,000.
Contacts
Insights
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.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
