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Regulatory Requirements Third-Party Service Provider

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

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The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

McDermott Will & Emery

New PCI DSS 4.0 Credit Card Compliance Requirements Effective April 1, 2025

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As of April 1, 2025, all merchants and third-party service providers (TPSPs) involved in processing credit or debit card payments must fully adhere to the enhanced security requirements outlined in the Payment Card Industry...more

A&O Shearman

EC publishes draft delegated regulation on subcontracting RTS under DORA

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On March 24 2025, the European Commission (EC) adopted the final draft Delegated Regulation setting out Regulatory Technical Standards (RTS) for subcontracting ICT services supporting critical or important functions under the...more

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

Goodwin on

On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more

K&L Gates LLP

Europe: National Regulators Announce Digital Operational Resilience Act Reporting Windows

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EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as...more

WilmerHale

FINRA’s 2025 Annual Regulatory Oversight Report: Focus on AI, Other Emerging Risk Areas, and Best Practices

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On January 28, 2025, FINRA published its Annual Regulatory Oversight Report (the Report). The Report highlights emerging risk areas and recent developments, common compliance deficiencies, and best practices for member firms....more

Hogan Lovells

The European Commission rejects draft Regulatory Technical Standards on subcontracting under the Digital Operational Resilience...

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What has happened: On 21 January 2025, the European Commission sent a letter to the Chair of the Joint Committee of the ESAs with its decision to reject the draft Regulatory Technical Standards (“RTS”) on subcontracting...more

Clark Hill PLC

What Debt Settlement Companies Need to Know When Working With Third Party Payment Processors (Whitepaper)

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Clark Hill’s Financial Services and Regulatory Compliance Group has authored a whitepaper for debt settlement companies considering engaging a third-party payment processor for managing accounts and handling financial...more

Benesch

Navigating Legal Liability in AI Adoption: What Healthcare Executives Need to Know

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The adoption of artificial intelligence (AI) in healthcare has ushered in a new era of innovation that is transforming diagnostics, treatment planning and operational efficiencies. However, with great potential comes...more

Hogan Lovells

DORA – One week to go

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The EU Digital Operational Resilience Act (“DORA”) is due to apply from 17 January 2025. It is designed to ensure regulated financial entities can withstand and recover from technology issues such as cyber events and...more

A&O Shearman

DORA: Get ready, get set, take action

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The Digital Operational Resilience Act 2022/2554 (DORA) is a European regulation that will come into force on January 17, 2025. The regulation aims to strengthen the digital operational resilience of the financial sector...more

A&O Shearman

European Supervisory Authorities Urge Financial Entities to Ensure Timely Compliance with EU Digital Operational Resilience Act

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The European Supervisory Authorities have published a joint statement on the application of the EU Digital Operational Resilience Act. The ESAs emphasise that as DORA does not provide for a transitional period, it is...more

BCLP

Managing Technology Supply Chains: What the Advent of the UK’s Critical Third Party Regime Means for Financial Services Firms and...

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The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector....more

Bracewell LLP

FINRA Facts and Trends: November 2024

Bracewell LLP on

Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting recent FINRA developments in the areas of enforcement, regulation and dispute resolution. This month,...more

Latham & Watkins LLP

UK Regulators Publish Final Rules for Critical Third Parties

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The new regime will take effect on 1 January 2025, but will not diminish the responsibilities of financial services firms relying on the services of critical third parties....more

Seyfarth Shaw LLP

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

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On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

BCLP

The EU’s Digital Operational Resilience Act 2022/2554 (DORA)

BCLP on

Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more

Walkers

Personal Information Protection Act deep dive

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The Personal Information Protection Act ("PIPA") comes into full force on 1 January 2025. All organisations in Bermuda are expected to be in compliance with it by that date – time is running out! The Privacy Commissioner...more

BCLP

Joining the Dots - Will the UK’s New Critical Third Party Rules Truly Move the Dial for Financial Institutions?

BCLP on

The announcement in 2021 of the intention to implement new rules directly targeting the types of tech service provider relied on by most financial institutions may be a necessary corrective given the heavy market...more

Barnea Jaffa Lande & Co.

Legal Guide for Implementing AI Tools in Organizations

Examining AI tools: Before deciding to purchase and implement AI tools in an organization, one must consider various aspects, including privacy issues, discrimination, copyright protection, and suppliers and contracts. The...more

Quarles & Brady LLP

Are You Ready for Alabama’s New Designated Representative Requirements?

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In a previous update, Quarles discussed a new Alabama law that requires individuals serving as the designated representative for an Alabama-licensed facility to register with the Alabama Board of Pharmacy ("the Board”) as of...more

Orrick, Herrington & Sutcliffe LLP

NYDFS revises proposed amendments to third-party debt collection rules

In December, NYDFS released revised proposed amendments to 23 NYCRR 1, which regulates third-party debt collectors and debt buyers. NYDFS first issued a proposed amendment to 23 NYCRR 1 in December 2021 ...more

Perkins Coie

The EU’s Digital Services Act: A Paradigm Shift for Online Intermediaries

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Following the European Council's approval last week, the Digital Services Act (DSA) has been officially adopted, starting the countdown to the law’s entry into force later this year. The DSA builds on the Electronic Commerce...more

Quarles & Brady LLP

The Clock is Ticking: Comments to Proposed Federal Rules For Wholesalers and 3PLs are Due June 6th and Here’s What We Think

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On February 4, 2022, the FDA released its long-awaited proposed national standards for the licensure of third party logistics providers (3PLs) and wholesale drug distributors. The draft rules were years over-due and the delay...more

Proskauer - Employee Benefits & Executive...

DOL Announces Temporary Enforcement Policy and Guidance to Address New Compensation Disclosure Requirements for Service Providers...

On December 30, 2021, the U.S. Department of Labor (“DOL”) issued Field Assistance Bulletin No. 2021-03 (“FAB”), announcing its temporary enforcement policy for group health plan service provider disclosures under ERISA...more

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