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US Department of Justice Criminal Division Announces New Pilot Program Encouraging Individual Voluntary Self-Disclosures

On April 15, 2024 the Criminal Division of the US Department of Justice (“DOJ”) launched a pilot program to encourage voluntary self-disclosures by offering mandatory non-prosecution agreements (“NPAs”) to individuals who...more

US DOJ’s National Security Division Updates Enforcement Policy for Criminal Sanctions and Export Control Violations with New Focus...

On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more

Commerce Considers ICTS-related Rules to Address Connected Vehicle Risks

On March 1, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (“BIS”) published an Advance Notice of Proposed Rulemaking1 (the “Notice”) seeking public comments on potential regulation of the...more

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

US Department of Justice Announces Sprint Towards New Whistleblower Reward Program

On March 7, 2024, the Deputy Attorney General of the US Department of Justice (“DOJ” or “Department”) announced a pilot program to encourage whistleblowers to report evidence of high-priority white collar crimes with the...more

President Biden Issues Executive Order Empowering DOJ to Regulate the Export of Sensitive Personal Data

On February 28, 2024, President Joe Biden issued Executive Order (“EO”) 14117, empowering the Department of Justice (DOJ) to regulate the export of certain consumer data, in order to prevent certain countries’ governments...more

US, EU and UK Adopt New Russia Sanctions and Export Controls as Ukraine War Hits Two-Year Mark

Following the invasion of Ukraine by Russia on February 24, 2022, the United States ("US"), the European Union ("EU"), and the United Kingdom ("UK") adopted—together with their allies—successive waves of sanctions, in an...more

Department of Commerce Seeks Comment on Proposed CIP Requirement and Foreign Access Restrictions for US Infrastructure as a...

On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more

New FTC and DOJ Antitrust Division Document Preservation Guidance Takes Aim At Collaboration Tools and Messaging Platforms

The FTC and DOJ’s Antitrust Division recently announced that they are updating their guidance regarding how parties in enforcement and investigative matters must preserve electronically stored information (“ESI”) from...more

BIS Announces Updates to the Voluntary Self-Disclosure Process

On January 16, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced important updates to its Voluntary Self-Disclosure (“VSD”) process in a memorandum addressed to all export enforcement...more

US DoD Proposes Final Rule for Cybersecurity Maturity Model Certification (CMMC)

On December 26, 2023, the Department of Defense (“DoD”) published the long-awaited Proposed Final Rule for the Cybersecurity Maturity Model Certification (“CMMC”) program. At a high level, the CMMC program is a mechanism by...more

The US Foreign Agents Registration Act (FARA): Key Issues to Watch in 2024

With recent high-profile prosecutions continuing to draw attention to the Foreign Agents Registration Act (FARA) and related political laws, and a number of notable announcements by Department of Justice (DOJ) officials at a...more

DOJ and FBI Announce Guidance on Seeking Delays in SEC 8-K Filings for Cyber Incidents

On December 12, 2023, the Department of Justice (DOJ) issued guidelines for companies to follow in requesting that the Attorney General authorize delays of cyber incident disclosures required by the U.S. Securities and...more

Cybersecurity Risks in Technology Transactions

Engaging third-party providers for technology transactions involves a certain level of cybersecurity risk. In fact, most companies have been through a third-party incident. In this episode, partners Justin Herring and Adam...more

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