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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors....more
On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs (“ECCP”) guidance. In a move that surprised no one (especially if companies have been reading...more
Almost seven months after seeking public comment on an initial proposed version, and more than seven years after first attempting to update its guidance on the issue, the Equal Employment Opportunity Commission issued on...more
On March 18, 2024, the U.S. Department of Health and Human Services Office for Civil Rights (HHS-OCR) revised its controversial December 2022 bulletin (the December 2022 Bulletin) regarding the use of tracking technologies by...more
On March 18, 2024, the US Department of Health and Human Services Office for Civil Rights (OCR) issued an update to its December 1, 2022, bulletin titled “Use of Online Tracking Technologies by HIPAA Covered Entities and...more
The U.S. Department of Health and Human Services Office for Civil Rights (OCR) issued updated guidance on March 18, 2024 regarding the use of online tracking technologies by entities and business associates covered by the...more
Artificial Intelligence (AI) is no longer just a buzzword, but a reality that is firmly on the radar of regulators and regulated firms in the US and UK. Recently, considerable investment into this area has prompted...more
The New York City Department of Consumer and Worker Protection (“DCWP”) has released its highly anticipated FAQs, providing additional guidance to employers seeking to comply with Local Law 144. As we discussed here and...more
The Federal Trade Commission’s Endorsement Guides were first enacted in 1980 and amended in 2009. The Guides provide guidance to businesses and others to ensure that advertising using endorsements or testimonials is...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
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 January 16, 2023, France’s financial prosecutor, the “Parquet National Financier” (PNF), issued updated guidance (the Guidelines) regarding its approach to offering, negotiating and entering into French deferred...more
The Occupational Safety and Health Administration (OSHA) has announced two enforcement guidance changes with the goal of deterring violations by substantially increasing the penalties certain employers may face for alleged...more
On October 18, 2022, the Eleventh Circuit Court of Appeals entered as its judgment its August 26, 2022 opinion limiting the scope of a nationwide injunction of the Biden Administration’s COVID-19 vaccine mandate for federal...more
New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more
On December 9, 2021, the Office of Management and Budget issued updated guidance to address the nationwide injunction that currently bars, on a preliminary basis, enforcement of the federal vaccine mandate. For federal...more
On August 12, 2021, New Orleans Mayor LaToya Cantrell and the City of New Orleans Health Department announced updated Guidelines for COVID-19 Reopening, which require individuals to provide proof of “having received at least...more
On September 10, 2020, the Commodities Futures Trading Commission (CFTC) issued the latest in a series of circulars regarding corporate compliance released this summer by government agencies. In June, the Criminal Division of...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
Last week, the US Department of Justice (DOJ) released its updated guidance on how prosecutors should evaluate corporate compliance programs. The revised guidance reiterates and expands on the hallmarks of successful...more
In the September 18, 2014 Federal Register, the Occupational Safety and Health Administration (“OSHA”) published revisions to 29 CFR Part 1904 with respect to updated reporting and recordkeeping requirements. Employers...more