SEC Activity with Fixed Income and Credit Funds
Podcast - Developments in FDA & DOJ Regulation and Enforcement of Manufacturer Communications
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
In December 2023, European Union (EU) lawmakers reached an agreement on the EU AI Act. In our article titled An Introduction to the EU AI Act, we focused on applicability, thresholds, timing, and penalties related to the EU...more
This blog post focuses on Artificial Intelligence (AI) practices prohibited under the EU AI Act. Article 5 of the AI Act essentially prohibits AI practices that materially distort peoples’ behavior or that raise serious...more
On March 13, 2024, the European Parliament approved the Artificial Intelligence (AI) Act. This law is the first-ever comprehensive legal framework on AI and will likely be a model around the world. The AI Act takes a...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
Insurance Ordinance amendments would create a risk-based capital regime aligned with international standards. On 6 April 2023, the Hong Kong government introduced the Insurance (Amendment) Bill 2023 into the Legislative...more
Amidst the recent surge in ransomware attacks on U.S. businesses—with crypto criminals and sometimes State actors invading and encrypting computer and operating systems and extorting funds in exchange for the decryption...more
The guiding principles are similar to related proposals from other banking regulators, but will require further clarification through the comment process. On December 2, 2022, the Board of Governors of the Federal...more
On January 1, 2023, the so-called Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz) (the “Act”) will go into effect in Germany. Many companies doing business in Germany will need to ready their compliance...more
With the recently adopted SDDA, Germany joins France in imposing human rights and environmental due diligence obligations along international supply chains of large companies. The SDDA covers companies based in Germany with...more
In early October, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory, warning of the potential risk of sanctions to companies and individuals who pay ransomware payments. The...more
On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory “to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...more
The rules and regulations governing private equity and hedge fund advisers continue to develop in response to changes in technology. As a result, advisers are subject to an ever-increasing degree of supervision by the...more
Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more
El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas. Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more
A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations. A Financial Institution’s OFAC compliance program is required to...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...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
The Situation: The LIBOR manipulation scandal and vanishing liquidity in the London inter-bank market for time deposits led the Financial Conduct Authority ("FCA") to announce that at the end of 2021, banks would no longer be...more
Wednesday, the U.S. Department of Commerce’s National Telecommunications and Information Administration (NTIA) issued a Request for Comments (RFC) on a new consumer privacy approach that is designed to focus on outcomes...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
New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...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