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Womble Bond Dickinson

DoD Must Embrace Crowdsourced Data to Maintain Battlefield Edge

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The Department of Defense stands at a critical crossroads in how it processes, authorizes, and utilizes data in operational environments. Despite living in an era of unprecedented information availability, our military...more

Venable LLP

Is Your Company's Overseas Bribery Prevention Program Still Necessary Under Trump's DOJ?

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A recent executive order (EO) and Department of Justice (DOJ) policy statement issued in the first weeks of February signal a potentially dramatic shift in the DOJ's approach to enforcing the Foreign Corrupt Practices Act...more

Akin Gump Strauss Hauer & Feld LLP

The First 100 Days

Most presidents spend the first days of their administration reversing the policies of their opposite party predecessor and laying the groundwork for their own policies with a series of executive orders. President Trump is...more

Mintz - Antitrust Viewpoints

AI Under a Second Trump Administration — AI: The Washington Report

Donald Trump’s election to a second term as president means that Trump will help shape the future of AI at a pivotal moment when AI continues to advance rapidly and the next administration’s policies will affect the future...more

Butler Snow LLP

The Not-So-Obvious Importance of International Anti-Corruption Programs: Protecting Companies and Individuals Against Perils Far...

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I remain amazed at the consistently-high estimates of the percentages of U.S. companies doing business internationally, which do not have FCPA and related anti-corruption policies and programs. Beyond the obvious and...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Davis Wright Tremaine LLP

All-In on AI: Bipartisan Senate AI Policy Roadmap Identifies Areas of Consensus

On March 15, 2024, the Bipartisan Senate Artificial Intelligence Working Group (the "AI Working Group")—led by Senate Majority Leader Chuck Schumer (D-N.Y.) and Sens. Mike Rounds (R-S.D.), Martin Heinrich (D-N.M.), and Todd...more

Akin Gump Strauss Hauer & Feld LLP

Senate AI Working Group Releases Long-Anticipated Roadmap for AI Policy

On May 15, 2024, the Senate AI Working Group—Senate Majority Leader Chuck Schumer (D-NY) and Sens. Mike Rounds (R-SD), Todd Young (R-IN), and Martin Heinrich (D-NM)—issued their long-anticipated Roadmap for Artificial...more

Akin Gump Strauss Hauer & Feld LLP

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Venable LLP

Nonprofits Operating Abroad: Five Key Compliance Strategies

Venable LLP on

With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

Seward & Kissel LLP on

The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

StoneTurn

Can Understanding Insider Risk Help to Prevent Fraud?

StoneTurn on

The UK government is moving towards introducing a new corporate criminal offence: Failure to Prevent Fraud and Money Laundering. The draft offence, contained in the Economic Crime and Corporate Transparency Bill, would hold...more

Latham & Watkins LLP

DOJ Announces Safe Harbor Policy for Voluntary SelfDisclosure of Criminal Misconduct Uncovered in M&A

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The policy expands upon DOJ’s efforts to encourage self-reporting of criminal violations discovered during M&A and other transactions. On October 4, 2023, US Deputy Attorney General Lisa Monaco announced a new Department...more

BakerHostetler

DOJ Announces Department-Wide Safe Harbor Policy for Voluntary Self-Disclosures Made in the Context of Mergers and Acquisitions

BakerHostetler on

In an important policy announcement aimed at rewarding robust due diligence and compliance programs, DOJ announced that acquiring companies that promptly and voluntarily disclose criminal misconduct discovered at the acquired...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

King & Spalding

Executive Order Establishes New Outbound Investment Screening Program

King & Spalding on

Prohibitions targeted to prevent China’s exploitation of dual-use technology - On August 9, 2023, President Biden signed a historic Executive Order on Addressing United States Investments in Certain National Security...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Adopts Final Cybersecurity Rules for Public Companies

In a narrow 3-2 decision on July 26, the SEC adopted its final rule concerning cybersecurity risk management, strategy, governance, and incident disclosure (the “Final Rule”).  Below we highlight some of the principal changes...more

Bass, Berry & Sims PLC

Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury

On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more

Torres Trade Law, PLLC

Trade Alert: Justice, Commerce, and Treasury Departments Issue a Tri-Seal Compliance Note on Voluntary Self-Disclosures

Torres Trade Law, PLLC on

On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more

Sheppard Mullin Richter & Hampton LLP

Where Do We Stand?: EU to US Data Transfers

The process for data transfers from the EU to the US under Standard Contractual Clauses has been back in the news recently, leading many to ask: will the proposed EU-US Data Privacy Framework be approved by the Europeans...more

Ankura

CFIUS Issues Enforcement and Penalty Guidelines Intended to Drive Compliance with FDI Reviews and Mitigation

Ankura on

On October 20, 2022, the Committee on Foreign Investment in the United States (CFIUS) issued new Enforcement and Penalty Guidelines (the “Guidelines”). CFIUS is an interagency committee that reviews and seeks to mitigate...more

Paul Hastings LLP

Another Step Forward to Implementing the European Union – U.S. Data Privacy Framework

Paul Hastings LLP on

On October 7th, the long-awaited Executive Order on Enhancing Safeguards for United States Signals Intelligence Activities was signed by U.S. President Joe Biden (Fact Sheet located here). The Executive Order directed the...more

Foley Hoag LLP - Security, Privacy and the...

U.S. Department of Homeland Security Launches First-Ever Cyber Safety Review Board

Earlier this week, the U.S. Department of Homeland Security (DHS) announced the establishment of the Cyber Safety Review Board (CSRB), as directed in President Biden’s Executive Order 14028 on Improving the Nation’s...more

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