On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more
The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies.
On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more
1/8/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Advisory Opinions ,
Biden Administration ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Executive Orders ,
Final Rules ,
Foreign Entities ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Reporting Requirements ,
Risk Management ,
Sensitive Personal Information
On December 19, 2024, the Department of Justice submitted a long-awaited Notice of Proposed Rulemaking (NPRM) to amend and clarify regulations issued under the Foreign Agents Registration Act (FARA). More than four years ago,...more
On February 28, 2024, President Biden signed Executive Order (EO) 14117 titled “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” On March 5,...more
4/1/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
Biden Administration ,
Biometric Information ,
Cyber Espionage ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
Geolocation ,
Health Insurance Portability and Accountability Act (HIPAA) ,
National Security ,
PHI ,
Popular ,
Risk Assessment ,
Sensitive Personal Information ,
Social Security Act
On December 18, 2023, new cybersecurity rules adopted by the U.S. Securities and Exchange Commission (SEC) became effective. Among other things, those rules require SEC registrants to disclose certain information about...more
On March 15, 2022, President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (the “Act”) as part of an omnibus appropriations bill. The Act compels “covered entities” — companies in...more
4/7/2022
/ Critical Infrastructure Sectors ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
FBI ,
Popular ,
Proposed Rules ,
Securities and Exchange Commission (SEC)
On October 6, the Deputy Attorney General (“DAG”) announced a new Department of Justice (“DOJ”) Civil Cyber-Fraud Initiative – an effort that pulls together attorneys and experts across DOJ focused on fraud enforcement,...more
FCA ENFORCEMENT SHIFT -
On October 6, the Deputy Attorney General (“DAG”) announced a new Department of Justice (“DOJ”) Civil Cyber-Fraud Initiative – an effort that pulls together attorneys and experts across DOJ focused on...more
10/19/2021
/ Cyber Incident Reporting ,
Cyber Threats ,
Cybersecurity ,
Department of Justice (DOJ) ,
Executive Orders ,
False Claims Act (FCA) ,
Fines ,
Fraud ,
Joe Biden ,
Popular ,
Whistleblowers
Department of Education Report Warns that Academic Institutions Are Failing to Meet Compliance Obligations in Fight Against Foreign Influence
Last month the Department of Education (“DOE” or “Department”) released an...more
11/23/2020
/ Accounting Controls ,
Audits ,
Compliance ,
Department of Defense (DOD) ,
Department of Education ,
Department of Energy (DOE) ,
Department of Justice (DOJ) ,
Educational Institutions ,
False Claims Act (FCA) ,
FBI ,
Foreign Entities ,
Higher Education Act ,
NASA ,
National Institute of Health (NIH) ,
National Security ,
Proposed Legislation ,
Reporting Requirements
In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more
3/12/2020
/ Anti-Money Laundering ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Cyber Crimes ,
Cybersecurity ,
Department of Justice (DOJ) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Law Enforcement ,
National Security ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
U.S. Treasury ,
Virtual Currency
The Department of Justice (DOJ) recently announced that it reached a $5,500,000 settlement with a biomedical research institute that received NIH grant funding–the Van Andel Research Institute (VARI)–to resolve allegations...more
2/26/2020
/ Department of Justice (DOJ) ,
Enforcement Actions ,
Failure To Disclose ,
False Claims Act (FCA) ,
Federal Grants ,
Foreign Investment ,
Government Investigations ,
Medical Research ,
National Institute of Health (NIH) ,
Research Funding ,
Settlement
On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more
1/17/2020
/ Department of Justice (DOJ) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
International Emergency Economic Powers Act (IEEPA) ,
International Sales ,
Non-Prosecution Agreements ,
Regulatory Requirements ,
Sanction Violations ,
Self-Disclosure Requirements