Last April, the C
riminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the Yates memorandum, provides structured incentives for companies to self-disclose, cooperate, and remediate with respect to FCPA violations. The remaining
Big Changes Come With The New Form I-9 Published by USCIS
United States Citizenship and Immigration Services (USCIS) has officially published the long awaited revised Form I-9. The new Form I-9 and instructions can be found at https://www.uscis.gov/i-9.
The clock is now ticking— While employers may begin using the new Form I-9 immediately, all employers are required to implement use of the newly revised Form
Tuesday’s GOP Wins May Put the Brakes on the CFPB’s Controversial Oversight of Auto Lending
The CFPB’s imposition of its auto lending guidelines, and use of its admittedly flawed proxy-methodology to determine discriminatory lending in auto finance, may come to an end under the GOP controlled White House and Senate.
The CFPB’s current guidance, published in a March 2013 Bulletin, has been largely criticized as limiting competition and increasing
UK set to shake up Corruption and Money Laundering Enforcement
The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law.
The Government hopes that the Bill “will significantly improve the government’s ability to tackle money laundering and corruption, recover the proceeds of crime, and counter terrorist financing”, and
How to prepare for the SEC’s Resource Extraction Disclosure Rule
After a long and tortured route through the courts, the SEC’s final rule implementing Dodd-Frank’s Resource Extraction Payment Disclosure requirement took effect today.
Many have watched and commented on the new Rule 13q-1, and for good reason. It is likely to have a significant impact — at least in the short term — on
CFPB Proposes Multiple Changes to TRID “Know Before You Owe” Rule
The Consumer Financial Protection Bureau (“CFPB”) recently issued 293 pages of proposed changes (the “Amendments”) to the federal mortgage disclosure requirements it propounded in October 2015 commonly known as the TILA/RESPA Integrated Disclosure (“TRID”) or “Know Before You Owe” rule. The changes are many, but the rulemaking is not intended to review policy decisions behind
Awaiting the Finale: France’s Debate Over Its New Anti-Corruption Law
France will soon change the anti-corruption landscape with a new law aimed at reducing foreign bribery. Finance Minister Michel Sapin introduced the new law in July 2015 with hopes of aligning France’s efforts with those of the U.S., UK, and other countries. The draft law was formally introduced in March 2016, but it has since
SEC Announces Settlement with Investment Advisory Firm Regarding Alleged Failure to Disclose Costs to Investors
On July 14, 2016, the Securities and Exchange Commission announced the settlement of an enforcement action against RiverFront Investment Group (“RiverFront”), an investment advisory firm, for failing to properly prepare clients for transaction costs.
At issue is a wrap fee program, in which a subadviser uses a sponsoring brokerage firm to execute their trades on
SEC Loses Chief of the SEC’s Office of the Whistleblower
On F
riday, July 8, 2016, the Securities and Exchange Commission (SEC) announced Sean McKessey, Chief of the SEC’s Office of the Whistleblower, will be leaving his post by the end of the month. Jane Norberg, Deputy Chief of the SEC’s Office of the Whistleblower will serve as Acting Chief until a replacement is found.
Prison Sentence for Executives in Contaminated Egg Case Highlights Food Safety Risks
Las
t Thursday, July 7, 2016, a divided panel of the U.S. Court of Appeals for the 8th Circuit upheld a three-month jail sentence against Austin “Jack” DeCoster and his son Peter, the CEO and COO respectively of Quality Egg LLC. The CDC determined that Quality Egg was responsible for a salmonella outbreak that ultimately