News & Analysis as of

Bad Actors

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

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In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

StoneTurn

NCSC Warns U.S. Startups and Investors of Foreign Bad Actors with Money to Spend

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Last week, the National Counterintelligence and Security Center (“NCSC”), the Office of Economic Security and Emerging Technologies (“OESET”) and other coordinating government agencies issued a warning to U.S. venture...more

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

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An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Wiley Rein LLP

Robocall Enforcement: Voice Providers Should Take Note of FCC’s New “C-CIST” Designation for Actors Posing a “Significant Threat”...

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On May 13, the Federal Communications Commission’s (FCC or Commission) Enforcement Bureau (Bureau) classified for the first time a group of entities and individuals – dubbed “Royal Tiger” – as a Consumer Communications...more

Arnall Golden Gregory LLP

Account Takeover and Business Email Compromise Fraud: Legally Puzzling Payments Problems

In a series of three articles, we will address the ascendency of account takeover (“ATO”) and business email compromise (“BEC”) fraud — the unfortunate occurrence where a payor or intended payee’s account is compromised,...more

American Conference Institute (ACI)

[Event] 12th Annual Forum on Dietary Supplements - June 25th - 26th, New York, NY

ACI and CRN are excited to welcome you back to New York City this Spring for our 12th Legal, Regulatory & Compliance Forum on Dietary Supplements. Network and collaborate with over 150 industry stakeholders to explore how...more

Rivkin Radler LLP

Trust Fund Recovery Penalty & The Closely Held Business

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Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2024 - De Minimis An Ever-Growing Problem of De Maximus Proportion

From Wikipedia: De minimis is a Latin expression meaning “pertaining to minimal things”, normally in the terms de minimis non curat praetor. (“The praetor does not concern himself with trifles”) or de minimis non curat lex...more

Wiley Rein LLP

7 Tips for Leveraging Artificial Intelligence While Managing Risks in Political Campaigns

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While its full potential is still untapped, artificial intelligence (AI) is poised to play a greater role during the 2024 elections and future grassroots advocacy efforts. Here are seven tips corporations and others should...more

Jackson Lewis P.C.

Multi-factor Authentication (MFA) Bypassed to Permit Data Breach

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As organizations continue to take steps to prevent cyberattacks, a near-universal recommendation is that they should implement multi-factor authentication (MFA), and for good reason. Organizations subject to the updated FTC...more

Ankura

U.S. Department of Commerce Issues Proposed Rule Impacting AI and U.S. IaaS Providers to Counter Foreign Malicious Actors

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On January 29, 2024, the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued a new proposed regulatory rule (the “Proposed Rule”), which will impose significant diligence, monitoring, and reporting...more

Cranfill Sumner LLP

Can the FTC Rein in AI Deepfakes?

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On February 15, 2024, the Federal Trade Commission (“FTC”) announced a supplemental Notice of Proposed Rulemaking (“NPRM”). The FTC has been the federal agency at the forefront of regulation in the Artificial Intelligence...more

Foley & Lardner LLP

CPSC Shares its Grand Plan at ICPHSO Annual Meeting

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The United States Consumer Product Safety Commission (CPSC) staff presented at several sessions during the International Consumer Product Health and Safety Organization’s (ICPHSO) annual meeting and training symposium in...more

Sherman & Howard L.L.C.

Alphabet Soup: FinCEN Proposal Would Add AML/CFT Obligations Under the BSA for RIAs & ERAs

Let me start by translating that headline to English. On February 15, 2024, the Financial Crimes Enforcement Network (FinCEN) division of the Department of Treasury issued a rule proposal that would require investment...more

Wiley Rein LLP

FTC Targets AI and Potentially More in Impersonation-Fraud Rulemaking

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On February 15, 2024, the Federal Trade Commission (FTC) issued a Supplemental Notice of Proposed Rulemaking (SNPRM) that proposes to hold liable entities that provide “goods or services” used by fraudsters to illegally...more

Moritt Hock & Hamroff LLP

Corporate Transparency Act Alert

Enacted as part of the federal Anti-Money Laundering Act of 2020, the Corporate Transparency Act (“CTA”) requires all entities formed or operating in the United States, with limited exemptions, to disclose certain information...more

Axinn, Veltrop & Harkrider LLP

Recognizing Risk: When Pursuing A Competitive Edge Creates Exposure to Trade Secret Claims

A well-known idiom - widely credited to Ben Franklin in the 1700s - is that an ounce of prevention is worth a pound of cure. Yet, few companies actively train their personnel to recognize the risk of a trade secret...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

Rivkin Radler LLP

Activities Contrary to Public Policy – Revoking the Tax Exempt Status of Universities

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It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more

Cozen O'Connor

23andme Is Asked to Confirm if Data Security Is Part of Its DNA

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Connecticut AG William Tong sent an inquiry letter to 23andMe, Inc. asking the genetic testing and ancestry company for more information regarding an October 6th press release in which it disclosed that customer profile...more

Davis Wright Tremaine LLP

Litigation Preparedness Following a Data Breach: Three Tips to Consider During the Incident Response Period

Data breaches come in many different forms, sizes, and levels of complexity, but they tend to share certain key facts: A third-party bad actor—whether through a phishing attack, a ransomware attack, exploitation of a zero-day...more

Mitratech Holdings, Inc

Aligning your cyber risk management program with your company’s bottom line

The key to gaining buy-in for your cyber risk roadmap under tightening budgets and staffing challenges. This statement should come as no surprise: there’s been an alarming rise in the number and sophistication of cyber...more

Wiley Rein LLP

Messaging at MWC 2023: Recapping an Afternoon at the ConnectMobile Forum

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Messaging is one of the most trusted forms of communications today, with more than 2.2 trillion texts exchanged on America’s wireless networks in 2022 alone. Yesterday, at CTIA’s ConnectMobile forum in Las Vegas as part of...more

Kohn, Kohn & Colapinto LLP

Gensler discusses markets “ripe with misconduct” and new SEC rules to address Changing Times

On September 12, the U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler testified before the U.S. Senate Committee on Banking, Housing, and Urban Affairs. His testimony emphasized that market growth combined...more

Miles Mediation & Arbitration

Mediating Negligent Security Cases: Issues and Strategies for Plaintiffs and Defendants

In the last few years, I have been fortunate to have attorneys and their clients trust me as their mediator in a significant number of high-exposure negligent security cases. Negligent security cases can offer a variety of...more

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