On August 25, 2016, the Federal Acquisition Regulatory Council issued final rules and the Department of Labor (DOL) published final guidance implementing President Obama’s 2014 “Fair Pay and Safe Workplaces” Executive Order (E.O.) 13673. The Executive Order requires covered federal contractors and subcontractors to report adversedeterminations under federal and state labor laws to federal agencies as part of the procurement process, and these violations can be used to find a contractor or subcontractor “nonresponsible,” preventing the contractor or subcontractor from receiving the contract. As a result, the Executive Order has been highly controversial and has become known in the contractor community as the “blacklisting” rule.