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Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

Recent FTO Designations Raise FCA Liability Concerns for Multinational Organizations

On February 20, 2025, the State Department designated multiple Mexican drug cartels and Transnational Criminal Organizations (“TCOs”) as foreign terrorist organizations (“FTOs”). At the same time, these groups were designated...more

State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State...

The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more

OCR Proposes Updates to Strengthen the HIPAA Security Rule

On December 27, 2024, the Office for Civil Rights (OCR) at HHS issued a Notice of Proposed Rulemaking (the Proposed Rule) intended to update the Security Rule under the Health Insurance Portability and Accountability Act...more

Proposed Changes to FARA Will Result in More Questions than Answers

On December 19, 2024, the Department of Justice submitted a long-awaited Notice of Proposed Rulemaking (NPRM) to amend and clarify regulations issued under the Foreign Agents Registration Act (FARA). More than four years ago,...more

New Data Center Validated End User Program Creates Pathway to Export Advanced U.S. Technology; Rigorous Review and Vetting...

Effective October 2, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), amended the Export Administration Regulations (EAR), 15 C.F.R. Parts 730 – 774, to expand the Validated End User (VEU)...more

Department of Justice Continues to Focus on AI This Week

On September 23, 2024, the U.S. Department of Justice (Department) announced that it had updated its guidance to prosecutors on how to evaluate the effectiveness of a corporation’s compliance program. The guidance, known as...more

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