Back on the (Sub-Supplier) Chain Gang…* (with apologies to The Pretenders) Do you know where your product was made? Not knowing…could be costly. Many U.S. businesses, large and small, sell merchandise that was manufactured or assembled, in whole or in part, in a foreign location. Most know about U.S. laws which prohibit buying goods, components, […]
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Steering Your Ship into the New M&A Safe Harbor Policy! Warning: you are steering into the treacherous waters of Bad Puns and Double Entendres. But don’t worry; we won’t leave you adrift (like a boat with no paddle). Let’s dive into this new policy position and its implications together, shall we? Consistent with last month’s
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What are the DOJ’s Evolving Requirements for Effective Compliance Programs? Answer: look at a recent Attachment C. What in Sam Hill is Attachment C? So glad you asked… When the US Department of Justice (DOJ) issues Foreign Corrupt Practices Act resolutions, they often include an “Attachment C.” You can consider Attachment C to be a
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The DOJ’s Whistleblower Pilot Program Does the Pilot Program undermine your compliance program? Newsflash! The US Department of Justice wants to pay you for leads! And in doing so, it could dangerously undermine incentives to internally report misconduct. In her keynote remarks at the American Bar Association’s 30th National Institute on White Collar Crime (March
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Maybe You Should Just Stop 7-Eleven is now the epicenter for store front crashes…and it’s costing them. From 2008 to date, over 6,000 cars have crashed into a 7-Eleven front. (This is roughly a crash every day.) In fact, 100+ drivers crash into storefronts every day; to date, 16,000 people have been injured and 2,600
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Santa Claus is Going to Jail Designed by Freepik Santa is known for his jolly holiday spirit and all-around goodness, but even Santa can’t outrun the law. The law has changed since we first pursued Mr. Claus and his Cannonball Run…so we’ve updated the analysis of his misbehavior as he navigates the world at
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UPDATE! New U.S. Beneficial Ownership Reporting Obligations Designed by Freepik Starting January 1, 2024, most US businesses will have one (1) year to file their Beneficial Ownership Report. As noted in our blog, “ALERT! Your New US Beneficial Ownership Reporting Obligations!”: beginning January 1, 2024, companies will be subject to increased reporting requirements. Specifically, new
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ALERT! Your New US Beneficial Ownership Reporting Obligations! Designed by Freepik Your questions: We’re glad you asked, read on for answers! The Genesis of Reporting Obligations Beginning January 1, 2024, companies will be subject to increased reporting requirements. Specifically, new regulations will require the reporting of information about company’s “beneficial owners” to the U.S. Treasury’s
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Groundhog Day for Data Privacy! (or, the revised, revised framework for EU-US data transfers) On July 10, the European Commission adopted its adequacy decision for the EU-US Data Privacy Framework (“EU-US DPF”). In short, the decision concluded that, in relation to personal data transferred from the EU to US companies, the United States framework provides
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A Robot Lawyer’s Guide to AI Hello, bipedal professionals! I am a robot lawyer powered by AI. I have just returned from working the chatbot chatrooms…and, boy are my plastic wing extensions tired! OK, agonizing jokes aside, there’s been a lot of, er, “chatter” about how AI is going to take over the legal profession. What are
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