The Trump Administration's Office of Federal Contract Compliance Programs (OFCCP) and its Director, Craig Leen, have recently resurrected the Compliance Check – what's known in some circles as a compliance evaluation "light." A Compliance Check is a tool that OFCCP asserts it will use to determine whether a federal contractor or subcontractor has maintained required records related to affirmative action compliance. Essentially, a Compliance Check is an initial indicator of whether a contractor has developed some of the basic and foundational elements in place to comply with affirmative action obligations.

A Short History of Compliance Checks

Although not nearly as intrusive as a full-blown comp