News & Analysis as of

Third-Party Risk Management

Benesch

Tracking Technology Trouble: Shah v. Capital One Deepens Legal Risk Under CCPA and CIPA

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In Shah v. Capital One Financial Corporation, the Northern District of California handed down a ruling that may shape the trajectory of litigation involving tracking technologies, online privacy policies, and California’s...more

Baker Botts L.L.P.

CCPA Class Actions Without a Data Breach; Courts Signal a New Litigation Frontier.

Baker Botts L.L.P. on

Two recent decisions from the Northern District of California—Shah v. Capital One Financial Corp., No. 24-cv-05985-TLT, 2025 WL 714252 (N.D. Cal. Mar. 3, 2025), and M.G. v. Therapymatch, Inc., No. 23-cv-04422-AMO, 2024 WL...more

Thomas Fox - Compliance Evangelist

Compliance Tip of the Day: Leveraging AI for Real-Time Third-Party Risk Management

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned...more

Morgan Lewis - Tech & Sourcing

Sourcing 360: Examining Troubled Digital Implementations and How the Contract Matters

Digital transformation continues to be a buzzword for 2025, with companies considering or implementing new user-facing and back-office artificial intelligence (AI) solutions and other digital tools to enhance end-user...more

Alston & Bird

Addressing Data Integrity Challenges in Medical Device Submissions

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The Food and Drug Administration’s (FDA) recent rejection of all study data from Mid-Link Testing highlights the importance of using reliable, valid data for medical device premarket submissions. Our FDA/Food, Drug & Device...more

Morrison & Foerster LLP

All Your Sale Are Belong to Us - Mitigating IP and Payments Risk in In-Game Economies

As in-game economies evolve, the complexity surrounding virtual goods and services, content creation, and payment structures deepens. As part of this ongoing series on in-game economies, this installment explores issues...more

Osano

The Privacy Insider Podcast Episode 12: Compliance Is Good Business: Getting Beyond Fines with Tom Fox of Compliance Podcast...

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AI and shifting regulations are dominating headlines, but a bigger transformation is happening in compliance—and businesses that fail to adapt will be left behind. Osano co-founder and Privacy Insider host Arlo Gilbert sits...more

Integreon

DORA Compliance Part 1: Proactively Meeting DORA Supply Chain Resilience Obligations

Integreon on

Introduction to DORA and its Implications - As of Jan.17, 2025, the European Union’s Digital Operational Resilience Act (DORA) became enforceable. This new regulatory framework significantly impacts financial institutions and...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

They’ll make the mistake and leave you to dry

At work and at home, one of the worst things I ever did was make a mistake and not accept responsibility for it. Instead of owning up, I would make excuses, turning the fight over the mistake into a bigger issue than the...more

Robinson+Cole Data Privacy + Security Insider

AI Governance: Steps to Adopt an AI Governance Program

There are many factors to consider when assisting clients with assessing the use of artificial intelligence (AI) tools in an organization and developing and implementing an AI Governance Program. Although adopting an AI...more

Skadden, Arps, Slate, Meagher & Flom LLP

FDA Contradicts Benzene Class Actions, Highlighting Risks of Third-Party Lab Testing

In March 2024, Valisure, an independent quality advocate, filed a citizen petition claiming to have detected elevated levels of benzene in benzoyl peroxide acne treatment products. Valisure’s petition included testing results...more

Ankura

Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

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2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more

Walkers

Fund Finance: Central Bank of Ireland relaxes regulatory prohibition on provision of third-party guarantees by QIAIFs

Walkers on

Subject to certain requirements, a QIAIF may now guarantee the obligations of third-party entities in respect of investments and/or intermediate vehicles in which the QIAIF has a direct or indirect economic interest. This is...more

Vedder Price

FINRA Publishes 2025 Regulatory Oversight Report

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On January 28, 2025, FINRA published its annual regulatory oversight report for 2025 (Report), which highlights observations and findings from FINRA’s oversight programs. The Report covers 24 topics, and for each topic it...more

Clark Hill PLC

The Growing Cybersecurity Risks in the Cannabis Industry

Clark Hill PLC on

Those familiar with the industry know that cannabis retailers find themselves in a unique position compared to other product retailers. Cannabis retailers face significant regulatory hurdles to their operation—particularly in...more

Mitratech Holdings, Inc

Red Flags In Your Vendor’s Business Continuity Plan

Ensure your vendors are crisis-ready by recognizing these key indicators of weak continuity planning. The interconnected nature of modern business means that your vendors’ operational resilience can, and frequently does,...more

Lowenstein Sandler LLP

Top AI Risks General Counsels Should Address

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Considering the rapid development and deployment of artificial intelligence (AI) in a wide array of applications and business sectors, it can be a daunting task for a company’s General Counsel (GC) to keep pace in identifying...more

A&O Shearman

European Commission rejects draft technical standards on sub-contracting ICT services under Digital Operational Resilience Act

A&O Shearman on

The European Commission has published a letter (dated 21 January 2025) addressed to the Joint Committee of the European Supervisory Authorities (ESAs) rejecting certain draft regulatory technical standards (RTS) the ESAs...more

Bracewell LLP

FINRA Facts and Trends: February 2025

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. We dedicate...more

Walkers

A comprehensive guide to the BMA's proposed new Operational Resilience and Outsourcing Code

Walkers on

In response to the increasing interconnectedness of financial service providers across global networks, the BMA is proposing to implement a new Operational Resilience and Outsourcing Code for regulated entities across all...more

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #430 – GrubHub Confirms Security Incident Through Third Party Vendor

If you are a GrubHub customer, read carefully. The app has confirmed a security incident involving a third-party vendor that allowed an unauthorized threat actor to access user contact information, including some customer...more

Carlton Fields

Will Insurers Be Required to Don a Deerstalker? The Case of Third-Party Vendors in Insurance

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Regulators are growing concerned about the delegation of various insurance company functions, prompting a closer examination of third-party vendors. Several groups within the National Association of Insurance Commissioners...more

BCLP

AI and Machine Learning in Financial Crime Compliance

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As financial crime risks evolve, including those risks posed by the use of AI and other emerging technologies, so too must firms’ financial crime compliance response. It is unsurprising, therefore, that AI forms part of both...more

Sheppard Mullin Richter & Hampton LLP

Looking Beyond FedRAMP – Lessons from the U.S. Treasury Cybersecurity Incident

In the ever-evolving world of cybersecurity, even organizations that meet stringent security standards can be victims of sophisticated cyberattacks. A notable example of this is the December 8, 2024 cybersecurity incident...more

K&L Gates LLP

Managing Artificial Intelligence: The Monetary Authority of Singapore's Recommendations on AI Model Risk Management

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Introduction and Background - On 5 December 2024, as part of the Monetary Authority of Singapore’s (MAS) incremental efforts to ensure responsible use of artificial intelligence (AI) in Singapore’s financial sector, MAS...more

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