Electronic I-9 software can be very attractive to companies looking for efficiency and ensuring compliance. Not to mention the elimination of file drawers that once housed these voluminous paper I-9 files. However, buyers beware, not all electronic I-9 software meets the federal regulations’ requirements. And the problem for well-meaning companies: ICE will still hold the
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Oral Arguments in PHH Case Signal Trouble for CFPB
The D.C. Circuit held oral arguments on April 12, 2016 in the case PHH Corp v. Consumer Financial Protection Bureau (CFPB), a case challenging the CFPB’s constitutionality as well as its interpretations of the Real Estate Procedures Settlement Act (RESPA), including its view that no statute of limitations applies to RESPA violations challenged by the
You Can Pay Your Lawyer: Supreme Court Recognizes Limits on Pretrial Asset Restraints
Before the U.S. Supreme Court’s ruling last week in Luis v. United States, the government could freeze a criminal defendant’s assets before trial even if they bore no connection to the alleged crimes. With the ruling, if the restraint prevents the defendant from paying for counsel, it violates the Sixth Amendment.
Sila Luis faced
The SFO’s “ongoing” investigation into Alstom – Further Charges
We originally wrote in 2014 about charges that had been brought in September of that year by the UK’s Serious Fraud Office against the French Multinational’s UK subsidiary, Alstom Network UK Ltd, and two former employees and British nationals for corruption offences (under pre-Bribery Act era legislation) relating to transport projects in India, Poland, and Tunisia.
Sharper Teeth for Sanctions Enforcement
The current UK sanctions enforcement regime is a complicated web reflecting the requirements of UN Security Council Regulations, EU Regulations, and UK Primary and Secondary Legislation. Penalties for breaches of sanctions are generally set out in the various statutory instruments that implement particular sanctions.
The UK Government, through the Policing and Crime Bill that is
CFPB Poised to Continue Focused Scrutiny of Indirect Auto Lenders
Earlier this month, the Consumer Financial Protection Bureau (CFPB) announced a joint enforcement action with the Department of Justice (DOJ) against Toyota Motor Credit Corporation (TMCC), an indirect auto lender, which, among other things, requires TMCC to pay $21.9 million in restitution to affected borrowers. Indirect auto lending is the most common type of auto
The SFO’s ‘Seize and Sift’ Procedure
R (on the application of Colin McKenzie) v Director of the Serious Fraud Office saw an unsuccessful attempt to judicially review the SFO’s currently in-use procedure for dealing with material that it has seized, and which may contain content subject to legal professional privilege (“LPP”).
This ‘procedure’, set out in the SFO’s Operational Handbook, provides
SEC Provides Guidance on 2016 Examination Areas of Focus
On Monday, January 11, 2016, the Securities and Exchange Commission (SEC) announced its Office of Compliance Inspections and Examinations’ (OCIE) areas of focus for 2016, which include:
- protecting retail investors and investors for retirement;
- assessing issues related to market-wide risks; and
- use of its ability to analyze data to identify and examine registrants that may
Conducting Internal I-9 Audits – ICE and DOJ-OSC Provide Joint Guidance
A company’s I-9 file, which often goes unnoticed by all but a few HR professionals, can carry significant risk. Form I-9 files often serve as landmines for fines, penalties, and sanctions. Companies can mitigate these risks by conducting periodic Form I-9 audits.
This week, the Department of Justice’s Civil Rights Division and the Department of Homeland
Proposed Changes to Form I-9 Create New Compliance Questions
Employers take note: a new Form I-9 is in the making. U.S. Citizenship and Immigration Services (USCIS), part of the Department of Homeland Security, announced on November 24, 2015, that it is seeking public comment on the various proposed changes. The proposed changes will have far-reaching impact because all employers are required to complete and