News & Analysis as of

Risk Factors Enforcement Actions

Woods Rogers

Heightened U.S. Border Scrutiny Poses Increased Digital Privacy Risk for Entrants to U.S.

Woods Rogers on

Foreign nationals visiting the United States, and even returning U.S. citizens and other legal residents (with valid visas), face increasing digital privacy risks and potential entry challenges when arriving at U.S. ports of...more

BCLP

U.S. Supreme Court Changes Its Mind, Will Not Decide Facebook Dispute Concerning Public Companies’ Risk-Factor Disclosures

BCLP on

After hearing argument earlier this month in a widely followed securities law case concerning risk-factor disclosures of public companies, the U.S. Supreme Court last week decided it should not have agreed to hear the case...more

McDermott Will & Emery

For the General Counsel’s Desk: Managing Enforcement Risks Involving Cookies, Pixels, and Other Tracking Technologies

McDermott Will & Emery on

Data governance is a mission-critical issue for every company and institution in the United States. GCs face a host of pressing cybersecurity concerns. Triaging them requires time, attention, and a well-rounded strategy...more

Bradley Arant Boult Cummings LLP

Washington Targets Loopholes for Sanctions Evasion: How to Mitigate Risks

Since the February 2022 Russian invasion of Ukraine, the U.S. has adopted a new, more aggressive sanctions strategy, increasingly going after parties who enable sanctioned businesses and individuals to conduct business and...more

Ankura

How Cybersecurity Protects Valuation: Considerations for Private Equity in the Deal Lifecycle

Ankura on

Cybersecurity risk applies to businesses of all sizes and across all industries – it is a risk that cannot be ignored. In particular, cybersecurity risk can no longer be ignored in the deal lifecycle...more

White & Case LLP

Updating Annual Report Risk Factors: Key Developments and Drafting Considerations for Public Companies

White & Case LLP on

The Annual Report season will soon be upon us, and it is important to assess a company's risk factors at the outset and whether recent developments, including those relating to macroeconomic, geopolitical, and public health...more

White & Case LLP

How to navigate the increase in financial crime risks during a downturn

White & Case LLP on

Financial crime flourishes in a downturn, and the mining & metals sector is not immune to it. The sector faces a number of industry-specific risks, and will need to react to the ensuing likely surge in enforcement activity....more

Bass, Berry & Sims PLC

OIG Declines to Approve Lab’s Payment of Specimen Collection Fees to Hospitals

On April 28, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services published Advisory Opinion 22-09, declining to approve a laboratory company’s proposal to pay hospitals a fair market...more

Fenwick & West LLP

OFAC Helps Those Who Help Themselves: How a Ransomware Response Plan Can Help Avoid Sanctions Enforcement for Ransom Payments

Fenwick & West LLP on

Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more

Sheppard Mullin Richter & Hampton LLP

Game On: FINRA Hints at Upcoming Gamification Sweep

During a May 19, 2021 webcast at the Financial Industry Regulatory Authority’s (“FINRA”) annual conference, Amy Sochard, FINRA’s Vice President of Advertising Regulation, indicated that the organization will seek public...more

ArentFox Schiff

Antitrust Enforcement in 2020 Offers Lessons for Associations in 2021

ArentFox Schiff on

Recent antitrust activity is instructive for associations to identify and limit key areas of antitrust risk. Here are some highlights from 2020: Certification and Accreditation Programs Are Pro-Competitive Functions of...more

Perkins Coie

Everalbum Settles FTC Claims Alleging Deceptive Use of Facial Recognition Technology

Perkins Coie on

The Federal Trade Commission (FTC) announced on January 11, 2021, that it had reached a settlement with Everalbum, Inc., the developer of a now-defunct photo storage app called “Ever.” The settlement is the FTC’s first...more

Herbert Smith Freehills Kramer

SEC-Mylan Settlement: The SEC Filed Suit Regarding Investigation Disclosure

On Sept. 27, 2019, the Securities and Exchange Commission (SEC) announced that Mylan N.V., a global pharma company that manufactures and sells EpiPen, which is used to treat serious allergic reactions, agreed to pay $30...more

Holland & Knight LLP

U.S. Securities and Exchange Commission Updates Cybersecurity Disclosure Guidance - Agency Continues to Prioritize Cybersecurity...

Holland & Knight LLP on

• The U.S. Securities and Exchange Commission (SEC) released, on Feb. 21, 2018, updated guidance regarding public company cybersecurity disclosures. The guidance updates the Commission's 2011 non-binding guidance and...more

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