Many businesses are already familiar with at least some of the employment-related risks associated with implementing and operating unpaid internship programs. As we detailed here, in light of guidance promulgated by the U.S. Department of Labor slightly more than four years ago, such programs now implicate and may trigger a host of wage and hour concerns.

On top of these burgeoning concerns, on June 14, a landmark New York City law – designed to protect interns from illicit workplace misconduct – takes effect. As we more fully detailed here, the impending law, ratified in April by Mayor Bill de Blasio, outlaws unlawful discrimination, harassment, and retaliation against unpaid interns based upon such interns' membership in one of the many protected classes enumerated by the New York City Human Rights Law. Akin to other provisions of the city's anti-discrimination ordinance, the law applies to all employers with four or more employees.

Employers should thus consult with counsel about the new law and, for those organizations that operate internship programs, any necessary revisions to handbooks and personnel policies.