With renewed enforcement of the Robinson-Patman Act against illegal price discrimination looming, direct-selling companies should reassess their pricing models. The FTC has made clear that tiered wholesale pricing, which gives higher-ranked distributors more favorable terms than their lower-ranked counterparts, can create significant legal risks under antitrust laws.

On July 25, 2025, the Internal Revenue Service (IRS or Service) released an Interim Guidance Memorandum dated July 23, 2025 (the IGM) that i) eliminates the Acknowledgement of Facts (AOF) Information Document Requests (IDR) from Large Business & International Division (LB&I) examinations, ii) provides updates on the changes to the Fast Track Settlements (FTS) pilot program, and iii) clarifies the applicability of Accelerated Issue Resolution (AIR) to Large Corporate Compliance (LCC) cases.

The U.S. Department of Commerce, through its Bureau of Industry and Security (BIS), continues to actively pursue investigations under Section 232 of the Trade Expansion Act of 1962. These investigations aim to determine whether specific imports threaten to impair U.S. national security. In recent months, BIS has significantly broadened the scope of its inquiries, reflecting heightened concerns over supply chain resilience, critical infrastructure, and technological competitiveness. This alert provides an overview of the currently active investigations and offers practical guidance for stakeholders, including how to participate in the public comment process.