Jenner & Block

Client Alert: Price Gouging and Law Enforcement: Is Your Compliance Program Ready?

As ongoing business disruption and consumer anxiety provoked by the Coronavirus (COVID-19) outbreak have led to shortages of certain critical goods, from N95 masks to food staples and hand sanitizer, efforts to take unfair advantage of the situation—in the form of hoarding and “price gouging”—are attracting the attention of law enforcement.  Some of the attention has focused on small-scale actors, like the ones in Tennessee who drew the attention of their State Attorney General for buying up thousands of bottles of hand sanitizer and thousands of packs of wipes, or the individual shops that have received cease-and-desist letters from an Attorney General for increasing prices on critical items. 

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