Transparency

News & Analysis as of

FinCEN Enhances Oversight Of Cross-Border Cash Movement

On August 1, FinCEN and its Mexican counterpart announced a series of reporting initiatives designed to improve the transparency of cross-border cash movements. To address U.S. and Mexican law enforcement’s concerns about...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more

Facebook asks its app developers for transparency

At this point, you’ve probably called your Candy Crush app every name in the book. (‘Annoying’, ‘addicting’, and ‘impossible’ are a few family-friendly ones that come to mind.) Now, Facebook is hoping you’ll be able to call...more

Treasury Issues Proposed Rules to Enhance Financial Transparency

On July 30, the Financial Crimes Enforcement Network of the U.S Department of the Treasury proposed rules under the Bank Secrecy Act to clarify and strengthen customer due diligence requirements for banks and other financial...more

Police and Body Cameras: Will Cameras Reduce Claims and Increase Transparency?

1600 hours: After briefing, the officer starts her shift. She straps on a body camera. But what next? Can the officer activate or deactivate the recording? Can the footage be deleted during her shift? What if the suspect, the...more

Corruption & Procurement: Bribery "Thrives in the Dark."

In the July 31, 2014 edition of the Jakarta Post there was a featured article “Smith & Wesson bribery scandal involves National Police officers,” which reported that “the Indonesian Corruption Watch (ICW) has called for an...more

The DISCLOSE Act: Fantasy or Future?

Following a wave of judicial decisions that have cleared the way for more soft money in politics, federal legislators have continued to press for the passage of laws creating more stringent regulations on donor disclosures...more

U.S. Appellate Court Raises Questions Regarding Transparency of CFIUS Process

The District of Columbia Court of Appeals, generally considered the most influential appellate court in the country on matters involving issues of governmental power, has resurrected a challenge by a Chinese-owned company to...more

ITC Section 337 Update – July 2014

Commission Enforcing General Policy In Favor Of Transparency With Respect To Settlement Agreements – On July 7, 2014, Administrative Law Judge E. James Gildea issued Order No. 66 in Certain Integrated Circuit Devices...more

Court Orders CFIUS to Increase Transparency but Rejects Review of Presidential Determination

A recent decision by the D.C. Circuit has prompted much speculation about possible changes to the traditionally opaque and secretive national security review process administered by the Committee on Foreign Investment in the...more

Revenue Sharing is becoming the 401(k) Leisure Suit

When I was a child, I remember bringing the soundtrack to Saturday Night Fever for my first grade class’ Chanukah party (I went to a Jewish day school). To this day, I still don’t how to operate a record player. Around the...more

UK Companies See The Value of The Code of Conduct As A Promotional Tool – Do You?

I came across this excellent article by The Red Flag Group called “Compliance Pulse: Codes of Conduct in the UK – A study of 100 codes of the largest companies listed on the London Stock Exchange.” The article outlines a...more

FTC Report Sheds Light on Dark World of Data Brokers

The Federal Trade Commission (“FTC”) recently issued a report entitled “Data Brokers: A Call for Transparency and Accountability” that identifies various concerns raised by the “Big Data” industry and provides solutions for...more

Commissioner Piwowar Slams “Dodd-Frank Politburo” for Overstepping Authority

In a speech on July 15, 2014, SEC Commissioner Michael S. Piwowar expressed his views about the Financial Stability Oversight Council (FSOC) operating in secrecy as it tries to expand its regulation of financial institutions...more

Swimming in the Deep End: A Primer on Dark Pools

“Dark pools of liquidity” have recently become the focus of increased regulatory scrutiny, including a number of high-profile enforcement actions related to these alternative trading systems. This increased scrutiny follows...more

Disclosing a CEO’s Illness: Privacy vs. Transparency

From time to time, a prominent CEO’s illness makes its way into the news and highlights once again one of disclosure’s trickiest issues. Most recently, Jamie Dimon, Chairman and CEO of JPMorgan Chase, disclosed that he has...more

Shelter from the Coming Storm: Anti-Corruption Compliance in European Public Procurement

A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four...more

Privacy Tuesday: July 2014 #2

FTC Sues Amazon Over In-App Purchases Made by Children - Children, according to Whitney Houston, are our future, but they are also, according to the Federal Trade Commission, willing to spend unlimited amounts of money...more

EC Posts Meeting Materials from Validation Workshop on Transparency Measures for Nanomaterials

The European Commission (EC) has posted materials from its June 30, 2014, validation workshop to discuss the preliminary results of the study supporting the impact assessment on transparency measures for nanomaterials. The EC...more

Transparency and Human Trafficking: Is Your Company Prepared?

Companies increasingly face expectations that they will “know and show” that they are taking appropriate steps to manage the human rights impacts associated with their business activities. New transparency requirements on...more

New York Enacts Out-Of-Network Transparency and Coverage Reform

Last month, a woman sued a health plan, claiming that she was intentionally misled about which physicians were participating providers in the company’s online health insurance exchange established under the Affordable Care...more

EC Posts Draft Reports for Impact Assessment on Transparency Measures for Nanomaterials

On June 30, 2014, the European Commission (EC) held a validation workshop to discuss the preliminary results of the study supporting the impact assessment on transparency measures for nanomaterials. As part of the workshop,...more

World Bank Suspension and Debarment Report

On June 26, 2014, the World Bank’s Office of Suspension and Debarment (OSD) released its public report covering sanctions arising from World Bank-financed projects during OSD’s first six years of operation. The report...more

‘Transparency and Trust’: Proposed Changes to Company Law in the UK

On 25 June 2014, the Government published the Small Business, Enterprise and Employment Bill. It includes a wide range of measures designed to improve the legislative environment for small businesses and incorporates...more

Snapshot of Sunshine Rules in EU Countries for The Pharmaceutical Industry

Since the enactment of the Physician Payments Sunshine Act (US Sunshine Act) by the United States, a number of EU Member States have adopted similar rules or strengthened pre-existing regulation in order to improve the...more

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