As we previously reported, the U.S. Department of Labor has published proposed guidance (“DOL Guidance”) and the Federal Acquisition Regulatory (“FAR”) Council has published proposed regulations (“FAR Proposed Rule”) implementing President Obama’s “Fair Pay and Safe Workplaces” Executive Order (E.O. 13673), often called the “Blacklisting” or “Bad Actors” executive order.  The Order requires government contractors and subcontractors to report regularly on workplace law violations found by administrative agencies, the courts, and arbitrators.

We’ve summarized the proposals and will continue to analyze each document and provide additional insights in the coming weeks.  Stay tuned.