On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more
The Corporate Transparency Act (CTA), the federal initiative to limit money laundering, tax evasion, and other illicit activities, took effect on Jan. 1, 2024. The CTA requires many businesses and their owners to register...more
In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
Employers had a big win in late June 2023 when a trial court in Sacramento enjoined until March 29, 2024, enforcement of the final regulations under the California Privacy Rights Act (CPRA), the only one of 14 recently...more
On December 26, 2023, the Department of Defense (“DoD”) published the long-awaited Proposed Final Rule for the Cybersecurity Maturity Model Certification (“CMMC”) program. At a high level, the CMMC program is a mechanism by...more
Data privacy and cybersecurity risks are critical components of M&A transactions due to the potential exposure for legal liability for non-compliance, as well as the financial and reputational harm and the material impact...more
Two months ago, the White House released its National Cybersecurity Strategy. Since then, various government agencies have issued new cybersecurity guidance for certain critical infrastructure subsectors. For example, the...more
Last month, on Data Privacy Day, Colorado’s Attorney General Philip Weiser released prepared remarks entitled “The Way Forward on Data Privacy and Data Security” that shed some light on his approach to enforcing Colorado’s...more
The U.S. Department of Justice announces an initiative targeting cybersecurity-related fraud by government contractors and grant recipients. On October 6, 2021, the U.S. Department of Justice ("DOJ") announced a new Civil...more
Investment Advisers - ANNUAL COMPLIANCE REVIEWS - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and procedures...more
I. Summary of effective dates - – Effective January 1, 2020 – Enforcement starting July 1, 2020 – Employees not covered for first 12 months*...more
On December 29, 2017, the Standardization Administration of China, jointly with the PRC General Administration of Quality Supervision, Inspection and Quarantine, issued the Information Security Technology – Personal...more
The European Union’s General Data Protection Regulation (commonly known as GDPR) has broad implications that reach even local public agencies in the United States. GDPR, which took effect May 25, is a sweeping global privacy...more
In January 2017, the IRS Large Business and International Division initially announced the launch of a “compliance campaign process” in which IRS identifies compliance issues that present risk and require a response in the...more
How does a company transfer data from the European Union (EU) to the US under the General Data Protection Regulation (GDPR) which went live on May 25, 2018? I recently had the opportunity to visit Jonathan Armstrong, partner...more
Data protection law is undergoing radical change that is impacting employers and trustees of pension schemes and all service providers to them. With effect from 25 May 2018 the European General Data Protection Regulation...more
Competition law is growing in Africa. According to a recent World Bank report, in 15 years the number of jurisdictions in Africa with competition law has almost trebled. A number of African countries have introduced or...more
The Federal Reserve announced on August 3, 2016, that it would fine Goldman Sachs $36.3 million in connection with a leak of confidential information from its New York branch. The leak was discovered and reported by Goldman...more
I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more