News & Analysis as of

Cooperative Compliance Regime

Holtzman Vogel Baran Torchinsky & Josefiak

In-Compliance: Holtzman Vogel's October 2024 Round-Up

FEC UPDATE - FEC Declines to Impose New Restriction on Joint Fundraising Committee Television Solicitations - On October 10, the FEC considered whether joint fundraising committees may distribute television...more

Society of Corporate Compliance and Ethics...

Corruption and modern slavery

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

CDF Labor Law LLP

California Legislation Requires More Transparency from Employers Utilizing Child Labor

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Earlier this week, California passed bill AB 3234 with ease in both the State Assembly (77-0) and the Senate (36-0). Governor Gavin Newsom is expected to sign the bill....more

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Dentons

Ep. 22 – Give Your Compliance Work Plan a 6-Month Check Up

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We are halfway through 2024, which means: now is the perfect time to evaluate your 2024 compliance initiatives and assess how you’re doing! It’s time to give your compliance work plan a 6-month check-up....more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

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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

Woods Rogers

Wax On, Wane Not: Corporate Investigations and Enforcement Actions are on the Rise at DOJ

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Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more

J.S. Held

INDEPTH FEATURE: Corporate Fraud & Corruption 2024

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To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more

Guidepost Solutions LLC

FTC Proposes Strengthening Children’s Privacy Rule

On January 11, 2024, the Federal Trade Commission (FTC) published a Notice of Proposed Rulemaking that would fortify the Children’s Online Privacy Protection Act (COPPA). This move underscores a significant shift in the...more

Ballard Spahr LLP

DOJ Launches Whistleblower Pilot Program and Cracks Down on AI Misuse

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The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more

Mayer Brown

Brasília Em Pauta – Edição Nº 146

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Pautas: STF – Controle Concentrado E Repercussão Geral | STJ – Repetitivos | TCU – Plenário | Câmara Dos Deputados | Senado Federal - ...more

Littler

Time for Employers to Complete California Privacy Rights Act Compliance as Court of Appeal Lifts Injunction on Enforcement

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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

Dentons

Ep. 3 - OIG’s New Approach to Compliance Guidance

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In November 2023, the United States Health & Human Services Officer of Inspector General (“OIG”) issued new compliance program guidance for the healthcare industry, referred to as the General Compliance Program Guidance...more

Dentons

Ep. 1 - Have You Created a Compliance Culture?

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Is your organization’s culture complimenting your healthcare compliance program? Does it enhance and maximize your program’s effectiveness?  Or, is your culture secretly sabotaging your compliance efforts?...more

Thomas Fox - Compliance Evangelist

Using a Root Cause Analysis for Remediation

The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more

Mayer Brown

US DoD Proposes Final Rule for Cybersecurity Maturity Model Certification (CMMC)

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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

GeoDataVision

Small Business Lending Market Rank & Share Report

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2022 CRA Aggregate & Disclosure Data was finally released last week, on December 21 by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as...more

The Volkov Law Group

HHS-OIG Guidance — Chock Full of Compliance Best Practices and Strategies (Part II of III)

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Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...more

Akerman LLP - Health Law Rx

Compliance Officers: Read the New OIG General Compliance Program Guidance!

The Office of Inspector General of the U.S. Department of Health and Human Services (the OIG) recently released an updated General Compliance Program Guidance document (GCPG). The GCPG has been anticipated since the OIG...more

Robinson+Cole Data Privacy + Security Insider

State Consumer Privacy Laws in M&A Deals: What to Know

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

Manatt, Phelps & Phillips, LLP

HHS OIG Unveils First New Compliance Program Guidance for Health Care Stakeholders Since 2008

The Big Picture - Many health care stakeholders have long relied on the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) guidance regarding an effective compliance program when...more

TNG Consulting

The Implications of Implementation Burdens for Title IX Officers and Students - Part IV: Burnout and Turnover Among Title IX...

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In the previous three newsletters, the authors reported about the recent challenges associated with the field moving towards a quasi-legal system. Yet, something we did not expand upon is how Title IX officers are coping with...more

Nelson Mullins Riley & Scarborough LLP

OIG Issues General Compliance Program Guidance

On November 6, 2023, the Department of Health and Human Services Office of Inspector General (OIG) issued General Compliance Program Guidance (GCPG) via publication on its website, which can be accessed by this link. The...more

Nossaman LLP

Compliance Notes - Vol. 4, Issue 20

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Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more

Polsinelli

Guidance for the ‘Burden of Cybersecurity Compliance’ Emerges

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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

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