SEC Activity with Fixed Income and Credit Funds
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Foreign device manufacturers should anticipate greater chance of FDA inspection under new FDA leadership
In this blog post, we will focus on obligations that the European Union’s Artificial Intelligence Act (AI Act) sets for deployers, providers, importers and distributors regarding high-risk AI systems....more
The EU AI Act is here, folks! Now that the Act has been officially published in the OJEU, it will go into force in 7 days on August 2, 2024. Now is the time to set your timers to align with the compliance calendar...more
In this blog post, we will focus on the identification of “high-risk AI systems” under the Artificial Intelligence Act (“AI Act”) and the requirements applying to such systems. As explained in our previous blog posts, the AI...more
The Bureau of Industry and Security (BIS) released its latest Don’t Let This Happen to You! report, summarizing recent U.S. export control civil and criminal enforcement actions....more
On March 13, 2024, European Union policymakers finally passed the long anticipated Artificial Intelligence Act (AI Act), the world’s first comprehensive artificial intelligence (AI) legislation, providing employers with...more
Yesterday, March 13, 2024, the European Parliament approved the EU Artificial Intelligence Act (“AI Act”), a sweeping AI governance framework which presents the first comprehensive law in the world aimed at ensuring AI...more
Who will play the leading role if we make a new series about AI? If you interview Steven Spielberg, Sundar Pichai, and Sam Altman, you might receive three distinct ideas ranging from the 2001 classic "AI: Artificial...more
On March 13, 2024, the EU AI Act received its final assent from the EU Parliament with 523 votes in favor, 46 against and 49 abstentions, bringing it one step closer to adoption. Minor linguistic changes are still to be...more
A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more
The rise of ransomware attacks has prompted the international community to explore a range of approaches to deter these attacks, including the use of sanctions, the further development and instantiation of norms governing...more
The task of designing appropriate third-party sanctions controls requires reverse engineering of relevant caselaw, particularly, the Epsilon Electronics case, which I reviewed in Part I of this series, and the Department of...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry. For seasoned compliance veterans, it ends up reading like a refresher...more
The Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) have recently stepped up the pressure on virtual currency companies. Increased regulatory scrutiny has largely taken the...more
Examine the Evolving Challenges That Lie Ahead for Healthcare Stakeholders and State Regulators—and What You Can Do Now to Prepare and Protect Your Organization—at a New Manatt Webinar. Effective health insurance...more
By using risk-based monitoring, you can begin to see things in “almost real-time, time-based trends of real data that you can then jump on and try to make adjustments before things get really wacky.” The implications to the...more
Recently Starbucks generated extremely negative news for having Philadelphia police arrest two persons who were waiting for a third person for a meeting. I want to use this most recent black eye for Starbucks and an earlier...more
I continue to explore the intersection of Sherlock Holmes, innovation and compliance by starting today with the story The Adventure of Silver Blaze....more
Today, I want to take a deep dive and exploration of the levels of due diligence. Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of...more
Under the Trump administration, foreign device manufacturers may see new compliance pressures and increased inspections by the FDA. In this video, Michael Heyl discusses this growing trend and shares insights on how foreign...more
This week I have devoted my blog posts to thinking about the management of risk by considering the tools of forecasting, risk assessment and risk-based monitoring. I have been assisted on this journey by Ben Locwin, Director...more
Today I continue my exploration of risk in compliance by starting a consideration of risk-based monitoring. As I have the previous two days, I honor a television star who died last week and today it is Mike Connors. While...more
Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more
In the last several years, the U.S. has been aggressively enforcing laws governing exports and international conduct. This is amply illustrated by the continuing imposition of large penalties on multinational companies for...more
Marc Wyatt, Acting Director of the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”), recently took part in a meeting of the ABA Hedge Fund Sub-Committee on November 20,...more