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Turkey: Amendments to PPP legislation on way

The Republic of Turkey has been undergoing a largescale reform in the healthcare sector in the past decade, spearheaded by the Ministry of Health under its Health Transformation Program which was launched in 2003. The EUR 20...more

French Anti-Corruption Reform Expected In 2016

France to introduce significant changes affecting large companies and top management, to improve current anti-bribery system. The French Parliament is expected to enact “Sapin II” on transparency, anti-corruption and...more

Hotels and Hospitality in Cuba: OFAC and Obama Paving the Way

With more flights, relaxing regulations, a historic presidential trip to Cuba, and news of hospitality services expanding into Cuba, the pathway into Cuba for hotels and hospitality companies seems smooth. But businesses...more

New Business Opportunities in Iran! Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for...

- Sanctions relief presents new business opportunities with Iran - Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies - The...more

Russian Legislation Update

Currency Control - On 5 April 2016 the President signed Federal Law No. 89-FZ amending the Administrative Offences Code. The limitation period for bringing administrative action for a breach of currency legislation...more

Breaking News: European Parliament Approves Trade Secrets Directive

On April 14, 2016 (by a vote of 503 to 131 with 18 abstentions), the European Parliament approved the text of a proposed Directive for the protection of trade secrets in the European Union. Once approved by the European...more

New EU Data Protection Regulation Is Now Enacted

On April 14, 2016, the European Parliament formally adopted the General Data Protection Regulation (GDPR). With this vote, the new EU data protection legal framework will become legally effective in two years and 20 days from...more

OFAC General License Facilitates Negotiations With Iran for Commercial Passenger Aircraft

Since we last spoke of "Implementation Day" established on January 16 under the Joint Comprehensive Plan of Action (see "Implementation Day" Brings Openings for Commercial Aircraft Sales With Iran advisory from January 22),...more

Privacy Shield Takes a Hit, While GDPR Gets A Boost

The past week has seen a number of key developments in the EU data protection regime – but it has not all been smooth sailing. First, the good news – on 8 April, the European Council formally adopted its position on the...more

EU Data Protection Authorities: Privacy Shield needs more work

European Data Protection Authorities have announced that, in their view, further work is required to ensure the proposed EU-US Privacy Shield provides sufficient protection to European data transferred to the United...more

Article 29 Working Party Calls for Improvements to the EU-U.S. Privacy Shield

On April 13, 2016, the body of European Data Protection Authorities (DPAs)—the "Article 29 Working Party" (WP29)—issued its opinion on the new EU-U.S. Privacy Shield.1 The WP29 acknowledged that progress has been made with...more

Key EU Advisory Body Declines to Support Privacy Shield

UPDATE: The Article 29 Working Party has released surprisingly brief comments on Privacy Shield. Consistent with the press briefing held on April 13, 2016, WP29 has concluded that Privacy Shield falls short without providing...more

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

Final text of the General Data Protection Regulation finally available

On 6 April 2016 the Council of the European Union has finally published what will most likely be the final text of the General Data Protection Regulation (GDPR), now translated in all the official languages of the EU....more

Cuba: A Playing Field for Trademark Pirates

Now that President Obama has lifted trade restrictions, American businesses are considering whether to expand their operations to Cuba. For some corporations, it makes immediate sense. For others, it may not. But regardless...more

Doing Business in Cuba Under the FCPA, Part V

Today, I conclude my weeklong exploration of doing business in Cuba from the perspective of the Foreign Corrupt Practices Act (FCPA) with some final observations. One of the key themes throughout this week’s blog posts has...more

Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There

The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President...more

Doing Business in Cuba Under the FCPA, Part IV

I continue my exploration of some of the issues around doing business in Cuba, from the Foreign Corrupt Practices Act (FCPA) perspective. Today I want to consider the types of ownership structures that are currently in place...more

Doing Business in Cuba Under the FCPA – Part III

I continue my exploration of the issues raised under the Foreign Corrupt Practices Act (FCPA) when doing or attempting to do business in Cuba. On Monday, I referred to the one person I am aware of you might consult for advice...more

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

Doing Business in Cuba Under the FCPA – Part II

Today, I continue my exploration of doing business in Cuba from the Foreign Corrupt Practices Act (FCPA) perspective. Yesterday, I made clear that anyone you do business with in Cuba is going to be a foreign official under...more

Legal revolution in France – civil law reforms (or Napoleon’s second coming)

This alert draws attention to the approaching entry into force of the new French civil code. This will be of interest to all parties with French law-governed agreements or that do business in France – especially regarding...more

Doing Business in Cuba Under the FCPA – Part I

I am back from a week of cultural and professional exchange in Cuba. It had been a lifelong dream of mine to go to Cuba and I hopped on the first trip I could enroll in after the travel for cultural exchanges were opened up...more

Please Read the Fine Print About Doing Business in Cuba

I am here to encourage newly authorized trade to and from Cuba. However, my job is also to ensure that exporters have all of the information they need to make informed business decisions and remain compliant with U.S. trade...more

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

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