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ARTICLE · 22 JUNE 2026

Update On DEI-Related Investigations And Settlements

Steptoe LLP
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Recent enforcement actions by the Department of Justice and state attorneys general signal heightened scrutiny of corporate diversity, equity, and inclusion programs, particularly those involving supplier diversity initiatives and investment programs.

United StatesEmployment and HR

In a recent client alert, Steptoe discussed a $17.1 million settlement between the Department of Justice (DOJ) and International Business Machines Corporation (IBM) over alleged False Claims Act violations related to IBM's Diversity, Equity, and Inclusion (DEI) practices. Since then, investigations of DEI practices in companies with government contracts have picked up at both the state and federal levels.

First, in May 2026, the Texas Attorney General issued a letter to CVS Health (CVS) warning it that the use of race- and/or sex-based quotas, including within its Supplier Diversity Program, may violate federal and state anti-discrimination laws and demanding a response within 14 days to avoid a potential Medicaid fraud investigation.1 Second, also in May, the DOJ reached a $30 million settlement with PayPal, Inc. (PayPal) that resolved allegations that PayPal's diversity-focused investment program unlawfully considered race and national origin in violation of the Equal Credit

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