Jeff Ifrah

Author

Latest Publications

Sarah Coffey

FTC Sends Message: Make Your Mobile App Secure

Mobile payments have become so commonplace that consumers rarely stop to think about whether their online payment is secure. Mobile app developers can fall into a similar trap of assuming that the necessary security measures are…more

Credit Karma, Fandango, FTC, Liability, Mobile Apps

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Michelle Cohen

Offshore Accounts? IRS is Watching

If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution. The IRS initially began this open-ended…more

FATCA, IRS, Offshore Banks, Offshore Funds, OVDP

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David Deitch

Are High Frequency Traders Playing Fast and Loose With the Rules?

When high frequency trading (HFT) first crept into the public consciousness, it related to primarily to the question of whether rapid, computer driven trading posed risks to the safety and stability of the trading markets. Now…more

CFTC, Fraud, High Frequency Trading, SEC

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Steven Eichorn

Banks Shy Away From Processing Marijuana Transactions in Colorado – Will Anyone Step Up?

Last Friday, the Department of Justice (DOJ) and the Department of Treasury, Financial Crimes Enforcement Network (FinCen), both published new guidance in connection with the legalization of recreational marijuana in Colorado…more

Banks, DOJ, FinCEN, Marijuana

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Griffin Finan

Don’t be a Jerk

Last week the Federal Trade Commission (“FTC”) charged the operators of Jerk.com with harvesting personal information from Facebook to create profiles for more than an estimated 73 million people, where they could not be labeled…more

Data Mining, FTC, Jerk

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Jeffrey Hamlin

Supreme Court Expands Whistleblower Protection

The U.S. Supreme Court recently held that Sarbanes–Oxley extends whistleblower protection, not just to employees of public companies, but to employees of private contractors and subcontractors that serve public companies. In a…more

Contractors, FMR LLC, Lawson v FMR, SCOTUS, Subcontractors

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Rachel Hirsch

New Year Brings New Plans by the FTC to Take Down Deceptive Weight Loss Advertisers

New year, new resolutions. Yesterday, the FTC announced a resolution of its own: to undertake a nationwide enforcement effort to protect consumers against deceptive weight loss claims. Dubbed “Operation Failed Resolution,” the…more

Advertising, Celebrity Endorsements, Endorsements, False Advertising, FTC

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Nicole Kardell

My, What Long Arms You Have, Uncle

Here’s a visual: Uncle Sam extending his arms around the world, reaching out for his citizens, wherever they may be. He may resemble a candy-striped Gumby, with disproportionately long rubbery arms spanning the globe. The visual…more

FATCA, IRS, Long Arm Statute, Tax Evasion

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Casselle Smith

FTC Secures Seven Figure Judgment Against Single Co-Defendant in Scareware Case

After the FTC secured a $163MM judgment against Kristy Ross in the US District Court of Maryland, the 4th Circuit affirmed, and so ends the FTC’s six-year “scareware” enforcement action. From beginning to end, this odyssey has…more

Enforcement, Enforcement Actions, FTC, Personal Liability, Section 5

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