Part 1 – Federal Contractors: Prepare for the Next Wave of Audits

EO 14398 and FAR 52.222-90 Signal a Major Shift in Federal Enforcement The federal contractor compliance landscape is undergoing one of its most significant transformations in decades. For years, contractors largely associated compliance oversight with affirmative action plans, OFCCP desk audits, and technical reporting obligations. Today, however, the federal government appears to be expanding its…
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A Federal Judge Dismissed a DEI Lawsuit Against Starbucks – Here’s What Federal Contractors Should Learn

A recent court decision involving Starbucks offers an important lesson for federal contractors navigating today’s DEI scrutiny: even in a politically charged environment, courts still require specific evidence of actual harm — not assumptions, headlines, or generalized allegations.  In the case, Missouri’s attorney general sued Starbucks, arguing that the company’s diversity, equity, and inclusion (DEI) initiatives unlawfully advantaged…
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Part I: The New Compliance Landscape Under EO 14173

In her recent remarks, former OFCCP Director Catherine Eschbach emphasized that the compliance environment for federal contractors is undergoing a profound transformation under Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” She explained that this order establishes a “whole-of-government approach” to identifying and eliminating unlawful DEI practices, meaning that oversight will no longer…
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Proactive Compliance in the Post-EO 14173 Era: A Practical Guide to Self-Auditing

Eight months after the issuance of Executive Order 14173, the federal contracting community has entered a new compliance era, one defined not by the creation of Affirmative Action Plans, but by the ability to prove nondiscrimination through certification. The transition from Executive Order 11246 to EO 14173 may have simplified paperwork, but it also raised…
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Enforcement Begins: Inside the EEOC’s post-EO 14173 Settlements

When Executive Order 14173 was issued in January 2025, many employers assumed that the revocation of Executive Order 11246 marked the end of federal oversight of affirmative action and diversity initiatives. Eight months later, that assumption has been proven dangerously wrong. While the structure of oversight has changed, enforcement has not disappeared. It has shifted….
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