Part 2: Before You Certify, Verify

A Pragmatic Compliance Framework for Federal Contractors The IBM and Deloitte settlements do not mean that contractors should stop conducting outreach, reviewing workforce data, or working to ensure equal employment opportunity. They demonstrate the importance of distinguishing between two very different activities: Using workforce data to identify and remove possible barriers; and Using protected characteristics…
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Part 1: When Civil Rights Compliance Becomes a False Claims Act Risk

How DOJ Is Connecting Civil-Rights Compliance to the False Claims Act Federal contractors are entering a new era of civil-rights enforcement. On August 25, 2026, Deloitte, a Federal Contractor, agreed to pay $21.5 million to resolve Department of Justice allegations that it violated the False Claims Act by certifying compliance with federal-contract nondiscrimination requirements while…
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