The Department of Justice’s (“DOJ”) Data Security Program (“the Program”, 28 C.F.R. Part 202) went into effect on April 8 with a 90-day period of limited enforcement. With DOJ now expecting full compliance, with additional...more
Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more
The Central Bank of Venezuela (BCV) through Resolution No. 19-05-01, published in the Official Gazette of the Bolivarian Republic of Venezuela No. 41.624 on May 2, 2019, authorized the creation of "exchange desks," by means...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more