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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
The updated guidance includes simplification measures allowing due diligence statements’ reuse, annual submission, and management by authorised representatives on behalf of companies....more
On March 12, 2025, the SEC published a No-Action Letter clarifying accredited investor verification requirements under Rule 506(c)....more
The New York State Department of Health (NYSDOH) in late February 2024 announced an update to its Guidance for Evaluating Soil Vapor Intrusion in the State of New York. For the first time, the Soil Vapor/Indoor Air Decision...more
In May, the Institutional Limited Partners Association (ILPA) introduced its long-awaited guidance on Continuation Funds. LPs have, in ILPA’s view, become “increasingly frustrated” with timeframes and economics in these...more
Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more
The Guidelines build on current social, environmental, and technological issues facing businesses following the last update in 2011. The Organisation for Economic Co-operation and Development (OECD) released updated...more
The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more
On 16 March 2023, the Office of Financial Sanctions Implementation (“OFSI”) published updated guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Guidance”). The Guidance now specifies...more
The UK Office of Financial Sanctions Implementation (OFSI) has issued long-awaited further guidance on ownership and control of entities by sanctioned persons. The new guidance was issued in an updated version of OFSI’s...more
On July 13, 2021, the US Department of State, US Department of the Treasury, US Department of Commerce, US Department of Homeland Security, Office of the United States Trade Representative, and US Department of Labor issued...more
Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more
Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more
On June 1, 2020, the U.S. Department of Justice (“DOJ”) released updated guidance entitled “Evaluation of Corporate Compliance Programs” (“Updated Guidance”), which provides the DOJ Criminal Division’s views on what comprises...more
On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published updated guidance intended to “enhance the availability of financial services” for the hemp industry (the Guidance). Even though the Agriculture...more
The Financial Crimes Enforcement Network (“FinCEN”) recently released guidance for bank and financial institutions regarding the requirements and obligations for financial institutions under the Bank Secrecy Act (BSA) and...more
I. INTRODUCTION - On 1 June 2020, the Criminal Division of the U.S. Department of Justice (DOJ) updated a critical guidance document, the “Evaluation of Corporate Compliance Programs” memorandum (“Guidance”), providing...more
The Department of Justice issued additional clarification and revised guidance on June 1, 2020, for corporate program compliance programs. The additional guidance doesn’t introduce substantive changes; however, it emphasizes...more
On June 1, 2020, the U.S. Department of Justice (“DOJ”) published a revised version of its guidance on the “Evaluation of Corporate Compliance Programs” (the “June 2020 Guidance”). Like its predecessors in February 2017 and...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more
On March 20, 2018, the U.S. Federal Trade Commission (FTC) issued updated guidance regarding compliance with antitrust laws for companies considering acquisitions, mergers, or joint ventures. While the FTC recognizes that...more
The SEC staff views social media as a useful tool that helps consumers conduct their own due diligence on investment advisers. In a recent Investment Management Guidance Update, the staff stated that, under certain...more