The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer. When cooler heads prevail, it is much easier to pick through the relevant issues and prioritize the issues and analysis. First, we need to put this in perspective. From a much larger viewpoint, the FCPA pause has to be considered...
In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice. The White House’s announcement seemed to take everyone by “surprise” but in the end was “expected” in light of recent announcements coming from Attorney General Bondi. The President’s Executive Order In an Executive Order that appeared...
On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States. By issuing his Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern, President Biden has directed the U.S. Department of Justice (“DOJ”),...
The Biden Administration issued a sweeping Executive Order directing a broad set of government actions addressing consumer harms, discrimination, privacy protections and other issues stemming from the widespread use of artificial intelligence. While the Executive Order sets forth a set of requirements to various federal agencies, the actions will establish important standards and expectations applicable to the federal government and have a resulting impact on...
On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia, issued sanctions against four entities and two individuals as part of a new sanctions program in Ethiopia. OFAC issued the sanctions is in response to humanitarian and human rights...
