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To Disclose or Not to Disclose (and how much) – That is the Question
The decision-making process involved in disclosing a cyber incident is a nuanced and delicate dance. Companies need to consider a myriad of factors, including when to disclose and how much detail to...
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UK Sanctions Update: New OFSI Reporting Requirements for High Value Dealers...
Late in 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), the agency within His Majesty’s Treasury that is charged with the implementation of financial sanctions in the UK,...
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Update on the Proposed Amendments to the Foreign Agents Registration Act...
On her very first day in office, Attorney General Pam Bondi issued a sweeping memorandum laying out what the Department of Justice’s (DOJ) enforcement priorities will be going forward under her...
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Trump Pauses FCPA Enforcement and Resets Priorities
On February 10, 2025, President Donald Trump issued an executive order titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (“FCPA EO”) that...
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The EU suspends certain Sanctions on Syria to support Economic Stabilization,...
To encourage democratic development and achieve a peaceful and inclusive political transition, and to aid the swift reconstruction and economic recovery of the country and facilitate its eventual...
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DOJ’S False Claims Act Based Civil Cyber-Fraud Initiative in 2024
The start of a new year presents an opportune time to reflect on the past. We have been tracking and reporting on the U.S. Department of Justice (“DOJ”)’s Civil Cyber-Fraud Initiative (“CCF...
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Friends Now, Foes Later – Written JDAs Are Critical to Protecting Clients in...
Multi-defendant criminal investigations present a classic prisoner’s dilemma. The parties would benefit from cooperating with one another but are incented to become adversaries, most often due to a...
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UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 2
Last month, the UK’s Office of Financial Sanctions Implementation’s (“OFSI”) published a Threat Assessment analyzing sanctions compliance involving UK financial services firms since February 2022,...
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Global Focus on Anti-Corruption Increases
While the United States has announced a pause on Foreign Corrupt Practices Act enforcement, the rest of the world is increasing its focus on prosecuting corrupt activities. This is a reminder to...
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Announcing The Inspector General Podcast
We are pleased to announce a new, quarterly podcast series: “The Inspector General.” Hosted by former State Department and Homeland Security Department Inspector General and partner in our...
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