SEC Activity with Fixed Income and Credit Funds
Podcast - Developments in FDA & DOJ Regulation and Enforcement of Manufacturer Communications
Foreign device manufacturers should anticipate greater chance of FDA inspection under new FDA leadership
In this blog post, we will focus on obligations that the European Union’s Artificial Intelligence Act (AI Act) sets for deployers, providers, importers and distributors regarding high-risk AI systems....more
On May 17, 2024, Colorado Governor Jared Polis signed, “with reservations,” Senate Bill 42-205, “Concerning Consumer Protections in Interactions with Artificial Intelligence Systems” (the Act). The first of its kind in the...more
A new era of AI legislation has begun as the EU AI Act enters into force on August 1, 2024. With broad extraterritorial reach, significant penalties of up to seven percent of worldwide annual turnover, and an emphasis on...more
In this blog post, we will focus on the identification of “high-risk AI systems” under the Artificial Intelligence Act (“AI Act”) and the requirements applying to such systems. As explained in our previous blog posts, the AI...more
On March 13, 2024, European Union policymakers finally passed the long anticipated Artificial Intelligence Act (AI Act), the world’s first comprehensive artificial intelligence (AI) legislation, providing employers with...more
On June 14, 2023, the European Parliament adopted its negotiating position regarding the proposal of the European Commission for a regulation laying down harmonized rules on artificial intelligence. This is the most recent...more
The task of designing appropriate third-party sanctions controls requires reverse engineering of relevant caselaw, particularly, the Epsilon Electronics case, which I reviewed in Part I of this series, and the Department of...more
Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more
OFAC (Oficina de Control de Activos Extranjeros) es un departamento del Tesoro de los Estados Unidos que administra y aplica sanciones económicas y comerciales basadas en la política exterior de los Estados Unidos y los...more
OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals. ...more
The Financial Action Task Force has published the outcomes of its third and last Plenary meeting under the U.S. Presidency in Orlando on June 19-21, 2019. The FATF considered key issues such as strategic initiatives, mutual...more
Recently Starbucks generated extremely negative news for having Philadelphia police arrest two persons who were waiting for a third person for a meeting. I want to use this most recent black eye for Starbucks and an earlier...more
New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more
Today, I want to take a deep dive and exploration of the levels of due diligence. Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of...more
This week I have devoted my blog posts to thinking about the management of risk by considering the tools of forecasting, risk assessment and risk-based monitoring. I have been assisted on this journey by Ben Locwin, Director...more
Today I continue my exploration of risk in compliance by starting a consideration of risk-based monitoring. As I have the previous two days, I honor a television star who died last week and today it is Mike Connors. While...more
Companies enjoying success in the U.S. often seek global expansion to gain strategic benefits from accessing new markets—new revenue potential, talent acquisition and increased brand awareness. Before replicating your...more
Progress on Final Rules implementing the Food Safety Modernization Act (FSMA) took a significant step forward last week when FDA released its first two, comprising the final rules on Current Good Manufacturing Practice and...more
In preparation for the audit of Canada’s anti-money laundering and terrorist financing regime by the Financial Action Task Force (FATF) in the fall of 2015, the Department of Finance and the Financial Transactions and Reports...more
Today, July 9, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) took two significant actions on the implementation of new regulatory capital requirements in the U.S....more