District court's denial of a motion to dismiss Indonesian fishers' Trafficking Victims Protection Reauthorization Act ("TVPRA") and California negligence claims—alleging that a U.S. company imported tuna harvested with forced...more
11/20/2025
/ Commercial Litigation ,
Corporate Counsel ,
Due Diligence ,
Extraterritoriality Rules ,
Forced Labor ,
Foreign Subsidiaries ,
Human Rights ,
Importers ,
Imports ,
International Labor Laws ,
International Trade ,
Jurisdiction ,
Motion to Dismiss ,
Negligence ,
Risk Management ,
Supply Chain ,
Trafficking ,
Trafficking Victims Protection Act of 2000
California's new Transparency in Frontier Artificial Intelligence Act creates the nation's first standardized safety disclosure framework for frontier AI models. On September 29, 2025, Governor Newsom signed the Transparency...more
10/27/2025
/ Artificial Intelligence ,
California ,
Disclosure Requirements ,
Innovative Technology ,
Machine Learning ,
New Legislation ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Transparency ,
Whistleblowers
Italy is the first EU Member State to enact national legislation on Artificial Intelligence ("AI"), thereby positioning itself as a frontrunner in shaping AI rule-making within the European Union....more
10/16/2025
/ AI Act ,
Artificial Intelligence ,
Data Centers ,
Data Privacy ,
Data Protection ,
EU ,
General Data Protection Regulation (GDPR) ,
Healthcare ,
Information Technology ,
Intellectual Property Protection ,
Italy ,
Machine Learning ,
New Legislation ,
Popular ,
Regulatory Reform ,
Regulatory Requirements
Artificial intelligence (“AI”) is a global subject of intense focus by governments, research institutions, investors, and corporations, ranging from start-ups to well-established industry leaders. As technology and regulatory...more
On January 1, 2026, California Assembly Bill 2013, the "Generative Artificial Intelligence Training Data Transparency Act" ("AB 2013"), will come into effect, requiring generative artificial intelligence ("GenAI") developers...more
9/18/2025
/ Artificial Intelligence ,
California ,
Data Privacy ,
Data Protection ,
Disclosure Requirements ,
Innovative Technology ,
Machine Learning ,
New Legislation ,
Regulatory Requirements ,
State Privacy Laws ,
Training ,
Transparency ,
Website Owner Liability ,
Websites
The European Union's Artificial Intelligence Act ("AI Act") establishes a comprehensive, risk-based regulatory framework including provisions relating to general-purpose AI ("GPAI") models that apply as from 2 August 2025. In...more
8/6/2025
/ Artificial Intelligence ,
Copyright ,
EU ,
European Commission ,
Innovative Technology ,
Machine Learning ,
New Legislation ,
Popular ,
Regulatory Requirements ,
Risk Management ,
Transparency
In response to President Trump's February 10, 2025, Executive Order pausing DOJ FCPA enforcement (the "Executive Order"), on June 9, 2025, the DOJ issued new guidelines (the "Guidelines"), which prioritize the enforcement of...more
6/18/2025
/ Anti-Corruption ,
Bribery ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Government Agencies ,
National Security ,
New Guidance ,
Regulatory Reform ,
Trump Administration
On May 12, 2025, the Department of Justice Criminal Division announced significant changes to its corporate white-collar criminal enforcement priorities. In line with the Trump administration’s recalibration toward...more
The Office of Management and Budget releases highly anticipated guidance to federal agencies on the use and deployment of artificial intelligence and how to manage its risks....more
5/7/2025
/ Artificial Intelligence ,
Executive Orders ,
Federal Contractors ,
Government Agencies ,
Machine Learning ,
National Security ,
New Guidance ,
OMB ,
Regulatory Requirements ,
Risk Management ,
Technology Sector ,
Trump Administration
The European Union's Artificial Intelligence Act ("AI Act"), the world's first comprehensive legal framework on AI, entered into force on August 1, 2024. The AI Act sets out staggered compliance deadlines for the various...more
On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the Foreign Corrupt Practices Act ("FCPA") by the U.S. Department of Justice ("DOJ") for 180 days and ordering Attorney General...more
The Situation: In September 2024, the U.S. Department of Justice ("DOJ" or "Department") announced updates to its Evaluation of Corporate Compliance Programs guidance covering three primary areas: (1) the risks of artificial...more
10/11/2024
/ Artificial Intelligence ,
Compliance ,
Compliance Management Systems ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Employees ,
Machine Learning ,
New Guidance ,
Risk Assessment ,
Risk Management ,
Safe Harbors ,
Whistleblower Protection Policies
The Development: On September 16, 2024, the U.S. Attorney's Office for the Northern District of Illinois ("NDIL") announced its six-month Individual Self-Disclosure Pilot Program for Organizational Misconduct ("Pilot...more
The Development: On August 1, 2024, the Department of Justice's ("DOJ") Criminal Division announced its Corporate Whistleblower Awards Pilot Program ("Pilot Program"), designed to reward whistleblowers who report information...more
8/20/2024
/ CFTC ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Money Laundering ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On May 17, 2024, Colorado enacted S.B. 24-205 (the "Act"), which imposes a duty of reasonable care on developers and deployers of high-risk artificial intelligence ("AI") systems to protect consumers from risks of algorithmic...more
The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more
On March 14, 2024, the United States Attorney's Office for the Northern District of California ("NDCA") revealed details of its new whistleblower pilot program ("NDCA Program")....more
The Development: On March 7, 2024, Deputy Attorney General ("DAG") Lisa Monaco discussed updates to the Department of Justice's ("DOJ" or "Department") corporate criminal enforcement policies and announced a pilot program...more
3/14/2024
/ Artificial Intelligence ,
CFTC ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Federal Pilot Programs ,
Money Laundering ,
Popular ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more
On October 30, 2023, President Biden signed a first-of-its-kind executive order entitled, "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence" ("AI")....more
11/1/2023
/ Algorithms ,
Artificial Intelligence ,
Biden Administration ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Department of Health and Human Services (HHS) ,
Executive Orders ,
Machine Learning ,
Regulatory Reform ,
Security Standards
In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
10/18/2023
/ CFTC ,
Compliance ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Electronic Communications ,
Financial Industry Regulatory Authority (FINRA) ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Workplace Communication
Under a new U.S. Department of Justice ("DOJ") policy related to mergers and acquisitions ("M&A"), DOJ will decline to prosecute an acquiring company for misconduct by an acquired company where the acquiring company timely...more
In Short -
The Situation: On June 26, 2023, the National Financial Reporting Authority of India ("NFRA") issued a circular reminding statutory auditors in India of their obligation under Indian law to report to the Indian...more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
8/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
The decision risks opening the door to increased forum shopping in states with consent-by-registration systems, but significant questions remain about the extent of those risks....more