In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more
Earlier this week, California passed bill AB 3234 with ease in both the State Assembly (77-0) and the Senate (36-0). Governor Gavin Newsom is expected to sign the bill....more
On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more
We are halfway through 2024, which means: now is the perfect time to evaluate your 2024 compliance initiatives and assess how you’re doing! It’s time to give your compliance work plan a 6-month check-up....more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more
To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
On January 11, 2024, the Federal Trade Commission (FTC) published a Notice of Proposed Rulemaking that would fortify the Children’s Online Privacy Protection Act (COPPA). This move underscores a significant shift in the...more
The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more
Pautas: STF – Controle Concentrado E Repercussão Geral | STJ – Repetitivos | TCU – Plenário | Câmara Dos Deputados | Senado Federal - ...more
Employers had a big win in late June 2023 when a trial court in Sacramento enjoined until March 29, 2024, enforcement of the final regulations under the California Privacy Rights Act (CPRA), the only one of 14 recently...more
In November 2023, the United States Health & Human Services Officer of Inspector General (“OIG”) issued new compliance program guidance for the healthcare industry, referred to as the General Compliance Program Guidance...more
Is your organization’s culture complimenting your healthcare compliance program? Does it enhance and maximize your program’s effectiveness? Or, is your culture secretly sabotaging your compliance efforts?...more
The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more
On December 26, 2023, the Department of Defense (“DoD”) published the long-awaited Proposed Final Rule for the Cybersecurity Maturity Model Certification (“CMMC”) program. At a high level, the CMMC program is a mechanism by...more
2022 CRA Aggregate & Disclosure Data was finally released last week, on December 21 by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as...more
Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...more
The Office of Inspector General of the U.S. Department of Health and Human Services (the OIG) recently released an updated General Compliance Program Guidance document (GCPG). The GCPG has been anticipated since the OIG...more
Data privacy and cybersecurity risks are critical components of M&A transactions due to the potential exposure for legal liability for non-compliance, as well as the financial and reputational harm and the material impact...more
The Big Picture - Many health care stakeholders have long relied on the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) guidance regarding an effective compliance program when...more
In the previous three newsletters, the authors reported about the recent challenges associated with the field moving towards a quasi-legal system. Yet, something we did not expand upon is how Title IX officers are coping with...more
On November 6, 2023, the Department of Health and Human Services Office of Inspector General (OIG) issued General Compliance Program Guidance (GCPG) via publication on its website, which can be accessed by this link. The...more
Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more
Two months ago, the White House released its National Cybersecurity Strategy. Since then, various government agencies have issued new cybersecurity guidance for certain critical infrastructure subsectors. For example, the...more
On February 22, 2023, the Department of Justice (DOJ) issued a press release highlighting the new Voluntary Self-Disclosure (VSD) Policy for U.S. Attorney’s Offices (USAOs). The DOJ developed this policy, which is applicable...more