On October 7, 2024, the Office of the General Counsel issued a new memorandum, GC 25-01, expanding her prosecutorial agenda to remedy what she sees as the harmful effects of non-compete agreements and so-called “stay-or-pay” provisions that violate the National Labor Relations Act (NLRA).

Last year, General Counsel Abruzzo issued memorandum GC Memo 23-08 stating her position that most non-compete agreements violate the NLRA because they tend to chill the exercise of Section 7 rights. And enforcement efforts against such agreements already underway, in particular a recent complaint issued by the GC. Recently, Region 22 issued a complaint against a building services contractor alleging the use of a no-poach agreement with its building clients violated the NLRA.