FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue
FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions
FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I
FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
On September 30, 2015, the CFPB ordered an indirect auto lending company and its auto lending subsidiary to pay $48.3 million in fines for alleged FDCPA, TILA, and UDAAP violations. The CFPB alleges that the companies...more
I was recently reading an article about a former UN consultant who was convicted and sentenced for conspiring to inflate prices for a UN contract to distribute pharmaceuticals to the DNC. As part of the investigation, e-mail...more
The legal relationship between business and the consumer will be fundamentally reshaped by the Consumer Rights Act 2015 (CRA), the key sections of which came into force on 1 October 2015.
This important piece of...more
The USPTO’s Welcome Initiative for Technology-Driven Changes in Registered Trademark Use.
Under a pilot program announced by the United States Patent and Trademark Office (USPTO) on September 1, 2015, trademark owners...more
Recent changes in cross-border leveraged loan documentation requirements open up new possibilities for both borrowers and lenders.
Cross-border leveraged loan documentation has become increasingly permissive with respect...more
On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more
eDiscovery lawyers like to say that a company’s first significant ediscovery matter will be their most expensive one. That’s because most companies don’t take the proactive steps that can minimize their exposure to ediscovery...more
As a leader of a start-up company, you are probably aware of the importance of protecting your company’s innovative products, services and technologies through patent filings. If you are savvy, you are also aware of the...more
A registered investment adviser agreed to settle SEC charges that it failed to adopt adequate cybersecurity policies and procedures reasonably designed to protect customer records and information as required by Rule 30(a) of...more
On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation...more
Why it matters -
Allegedly deceptive enrollment tactics by third-party marketers cost the issuer of healthcare credit cards $700,000 in a settlement with the Consumer Financial Protection Bureau (CFPB). Springstone...more
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more
No Need to Wait for the U.S. Supreme Court—Seventh Circuit Rules on Mooting Offers in TCPA Suits -
The latest court to weigh in on an offer of judgment in a Telephone Consumer Protection Act Suit: the Seventh Circuit...more
On September 15, 2015, the Security and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide additional information on the areas of focus for its second round of...more
Second Round of Cybersecurity Examinations to Begin -
On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a...more
With headlines every day announcing another release of Protected Health Information (PHI), providers are asking themselves – is there a way to protect against these breaches?
Beyond improving the security of large...more
The New Jersey Supreme Court recently held that an automobile insurer must pay an innocent third party the contracted $10,000 amount of basic coverage following an auto accident involving the insured’s vehicle, despite that...more
On September 15, 2015, OCIE issued a risk alert relating to its new cybersecurity examination initiative. This is the second round of these examinations, and the alert provides a detailed look at OCIE’s current areas of...more
One of the more dramatic privacy law developments in China in 2014 was the August criminal conviction of foreign nationals Peter Humphrey and Yu Yingzeng for their violation of Article 253 of the Criminal Law (??) associated...more
In late August the U.S. Court of Appeals for the Second Circuit reinstated a lawsuit by a physician association against a third-party plan administrator. The case against UnitedHealth Group and related entities (United) had...more
Companies are reminded of the need for strong internal controls.
The US Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) recently filed civil and criminal actions in the largest hacking and...more
The Social Security and Tax Number (“My Number”) System (the “System”) will go into effect in January 2016, and the government will start distributing My Numbers to all citizens in October 2015. The Act on the Use of Numbers...more
In France, a procedure exists whereby a third party (X) affected by a judgement between two other parties (Y,Z), may challenge that judgement by way of third party action (tierce opposition), where that...more
The Minnesota State Fair continues to provide endless blog fodder for those who care about intellectual property. Last week, we wrote about a State Fair vendor concerned about its claimed, but unarticulated “intellectual...more
A new bill unanimously passed the U.S. Senate in July that could make it significantly more difficult for general counsel when considering whether to self-report antitrust issues. The Criminal Antitrust Anti-Retaliation Act...more
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