The final text of the amended Negative Option Rule, featuring the new “Click to Cancel” program, goes into effect this week on Wednesday, January 15, 2025, and should become enforceable approximately four months later on...more
1/14/2025
/ Amended Rules ,
California ,
Compliance ,
Consumer Protection Laws ,
Corporate Counsel ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Final Rules ,
FTC Act ,
Regulatory Reform ,
State Attorneys General ,
Unfair or Deceptive Trade Practices
Unfortunately, but as predicted earlier this year, the Department of Justice (DOJ) has shown no signs of pausing use of the False Claims Act (FCA) as a tool to enforce cybersecurity compliance.
On September 5, 2023, DOJ...more
On March 3, the Criminal Division of the Department of Justice announced a two-part pilot program to encourage corporations to implement compliance programs with provisions for employee compensation incentives and clawbacks...more
3/7/2023
/ Bad Actors ,
Clawbacks ,
Compliance ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Executive Compensation ,
Incentive Compensation ,
Pilot Programs ,
Regulatory Agenda ,
White Collar Crimes
On February 22, 2023 the Department of Justice (DOJ) released a new policy governing self-disclosure of corporate criminal wrongdoing to United States Attorney’s Offices (USAOs). The policy entitled “United States Attorney’s...more