On May 30, 2023, National Labor Relations Board (“NLRB”) General Counsel Jennifer Abruzzo took yet another step to ban restrictive covenants in the employment context. In a memo issued to all regional offices, she set forth her view that nearly all non-compete provisions, with very limited exceptions, violate the National Labor Relations Act (“NLRA”). Although GC Abruzzo’s memo is not binding law, as we’ve previously reported, the issuance of the memo is the latest in a series of aggressive governmental efforts, including from the Federal Trade Commission and the Department of Justice’s Antitrust Division, to curb the use of non-compete agreements, which typically restrict employees from working for a competitor or opening a competing business.