Searching Content indexed under Compliance by Cleary Gottlieb Steen & Hamilton LLP ordered by Published Date Descending.
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SEC's OCIE Affiliate Transaction Risk Alert Highlights Pitfalls In Obtaining Effective Consent
On September 4, 2019, the SEC's Office of Compliance Inspections and Examinations ("OCIE") issued a Risk Alert addressing the most common compliance issues it identified in examinations of ...
United States
14 Oct 2019
California Consumer Privacy Act Amendments Offer Relief, But Challenges Remain
California's 2019 legislative session has drawn to a close with passage of five amendments to the California Consumer Privacy Act (CCPA) during the final days of the session.
United States
7 Oct 2019
Agencies Adopt Final Rule Implementing Key Elements of Volcker 2.0
On August 20, 2019, two of the agencies responsible for implementing the Volcker Rule finalized amendments to the Rule that narrow and simplify the proprietary trading prohibition
United States
2 Sep 2019
Agencies Finalize Elements Of Volcker 2.0
On August 20, 2019, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency approved a Final Rule adopting key changes to the proprietary trading
United States
23 Aug 2019
Rule 21F–17: Guidance On Drafting Confidentiality And Non-Disclosure Agreements
Global Crisis Management Series: This post is part 9 in a series concerning topics further elaborated on in Cleary Gottlieb's Global Crisis Management
United States
16 Aug 2019
Five Building Blocks For Effective Internal Controls To Comply With U.S. Whistleblower Protections
In addition, anti-retaliation policies should outline how the company receives and responds to employees' compliance concerns.
United States
16 Aug 2019
July 2019 Privacy And Cybersecurity Enforcement: Lessons For Management And Directors
In late July 2019, U.S. federal and state regulators announced three headline‑grabbing data privacy and cybersecurity enforcement actions against Equifax and Facebook.
United States
16 Aug 2019
Disclosure And Notification Considerations When Managing A Crisis
Effectively dealing with a crisis often requires disclosure to government authorities, shareholders, and other stakeholders, even when many facts remain unknown.
United States
19 Jul 2019
SEC To Allow Settling Parties To Submit Simultaneous Settlement Offers And Applications For Waiver From Disqualifications
On July 3, SEC Chairman Jay Clayton issued a statement signaling a policy change in SEC settlements and the consideration of applications for waiver of collateral consequences flowing from those settlements, ...
United States
15 Jul 2019
SEC Privacy Risk Alert May Foreshadow Upcoming Reg S-P Enforcement Against Broker-Dealers, Investment Advisers
In the Risk Alert, OCIE indicated it had frequently identified deficiencies with regard to Firms' provision of adequate notice to their customers.
United States
20 Jun 2019
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