TTB: Generous Payment Terms Violate Federal Law
Under the Federal Alcohol Administration Act’s unfair competition and unlawful practices statute (27 US Code Section 205), alcohol suppliers are prohibited from selling alcohol to wholesalers and retailers on consignment. The TTB recently released Industry Circular 2022-1, which discusses the TTB’s position that long payment terms may violate the federal anti-consignment law. Federal Law Prohibits Anti-Competitive Arrangements Under Section...
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