News & Analysis as of

Third-Party Compliance

BCLP

Possible Reprieve on Federal PFAS Reporting Under TSCA: US EPA Issues Direct Final Rule Extending TSCA PFAS Reporting Deadlines

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Companies subject to the Toxic Substances Control Act (“TSCA”) Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (“PFAS”)—also known as the “TSCA PFAS Reporting...more

BCLP

EHRC Draft Technical Guidance - Clear Messaging on Sexual Harassment

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Welcome to the new Two Minute Weekly. Following requests from readers, we are changing the format of our employment law newsletter. It will now be weekly and will feature as it did before news items and new cases....more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

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Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

BakerHostetler

FTC Continues Focus on Disclosure of Health Information to Third-Party Technologies

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A recently announced settlement with online alcohol addiction treatment service Monument Inc. demonstrates the Federal Trade Commission’s (FTC) continued focus on the use and disclosure of health data. The proposed settlement...more

Pillsbury Winthrop Shaw Pittman LLP

Working Around OSHA’s New Walkaround Rule

After May 31, 2024, employees can designate a non-employee to accompany OSHA compliance officers during worksite inspections. OSHA inspectors will determine whether non-employee representatives are “reasonably necessary”...more

NAVEX

Compliance & Cybersecurity – Working and Worrying Together About the Intersection of People and Technology

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I’m not a cyber expert, but as a compliance professional with accountability for internal investigations of employee and third-party misconduct I’ve had a front row seat to the evolution of risk that has mirrored the mass...more

Foley & Lardner LLP

Employers Take Note: OSHA Publishes Final “Walkaround” Rules

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On April 1, 2024, the U.S. Department of Labor (DOL) published its final rule on who is allowed to be present for an OSHA inspection. The rule becomes effective on May 31, 2024. By way of background, both the employer and...more

Integreon

Thomson Reuters: Achieving Compliance With Your Law Enforcement and Third-party Subpoena Response Process

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This article originally appeared on Thomson Reuters Westlaw Today on February 12, 2024. View the original article here. Robert Daniel and Mark Grant of Integreon, Inc. explore areas legal operations professionals should...more

WilmerHale

California AG Announces Second CCPA Enforcement Action

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On February 21, the California Attorney General (“AG”) announced a settlement with DoorDash, an online food delivery service, to resolve allegations that the company violated the California Consumer Privacy Act (CCPA) and...more

Thomas Fox - Compliance Evangelist

Pre-taliation Protection Extends to Third Parties

The Securities and Exchange Commission (SEC) has been cracking down on companies that engage in pre-taliation, imposing increasing fines as a result. This was evident in the recent case of JP Morgan,  which faced an $18...more

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

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A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

NAVEX

SEC Rule or Not, Keep Your Eye on the Climate Change Ball

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The U.S. Securities and Exchange Commission recently announced that its long-awaited greenhouse gas disclosure rule will be delayed yet again, most likely until April 2024. This raises an important question for compliance and...more

NAVEX

Understanding the Updates and Implications of the EU Corporate Sustainability Due Diligence Directive

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On February 23, 2022, the European Commission released a proposal for the Corporate Sustainability Due Diligence Directive (CSDDD or the Directive). The Directive aims to mandate both EU and non-EU companies that conduct...more

Adams and Reese LLP

FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area

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Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part II)

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In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - November 2023 - Employee Education in Compliance Training

Employee education supports organizational growth and development. Its benefits are generally well known, but how do you ensure that training, in any form, generates the outcomes and advances you desire? Measuring and...more

Sheppard Mullin Richter & Hampton LLP

NY Federal Court Rules CFPB Vicarious Liability Suit Can Proceed

In August, a New York federal district court denied a motion to dismiss a CFPB lawsuit against three affiliated companies engaged in the business of purchasing distressed consumer debt and several of the companies’ owners and...more

A&O Shearman

DOJ Cracks Down on Third Party Information Benchmarking

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On September 28, 2023, the Department of Justice (DOJ) launched a civil suit against a benchmarking service provider that signals a crack-down on benchmarking involving the exchange of competitively sensitive information. ...more

Thomas Fox - Compliance Evangelist

One Month to More Effective Written Standards: Day 17 – Policies for Third-Parties

As every compliance practitioner is well aware, third-parties still present the highest risk under the FCPA. The DOJ 2023 ECCP devotes an entire prong to third-party management. It begins with the following: A well-designed...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - December 11th - 14th, Orlando, FL

Designed for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy is ideal for practitioners who want a deeper understanding of effective compliance management in a...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Perkins Coie

Ten Considerations for Developing an Effective Generative AI Use Policy

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This year’s news has been full of stories about “generative” artificial intelligence (AI) applications. Generative AI tools create code, text, images, and other content in response to text prompts, queries, and other inputs....more

Reveal

CCPA Compliance Checklist [Ultimate 2023 Edition]

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“We hope today’s settlement sends a strong message to businesses that are still failing to comply with California’s consumer privacy law. My office is watching, and we will hold you accountable.” These were the words of...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - August 21st - 24th, Washington, DC

Designed for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy is ideal for practitioners who want a deeper understanding of effective compliance management in a...more

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