The Three Certification Layers Every Federal Contractor Must Know

“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 2 OF 4 Part 1 covered what changed. This brief: the three layers contractors certify today. Recap: Executive Orders 14173 and 14398 replaced the old EO 11246 affirmative-action framework with a certification-based model, enforceable through the False Claims Act. Here’s how that model actually works, layer by…
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PART 1 – EO 14398 & FAR 52.222-90: Nondiscrimination Enters the Federal Procurement Process

The federal contractor nondiscrimination landscape has evolved significantly. Following recent federal procurement changes associated with Executive Orders 14173 and 14398, Addressing DEI Discrimination by Federal Contractors, the FAR Council introduced FAR 52.222-90, Addressing DEI Discrimination by Federal Contractors (APR 2026). The significance for federal contractors is substantial: nondiscrimination requirements are now being incorporated directly into…
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Part I: What Recent DOJ Investigations Reveal About Compliance Risks for Federal Contractors

Recent actions by the U.S. Department of Justice (DOJ) should serve as a wake-up call for federal contractors and employers nationwide. In June 2026, the DOJ launched an investigation into alleged race discrimination at the City University of New York (CUNY) involving its Black Male Initiative program. The Department is examining whether educational opportunities and…
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