The Department of Justice has published new guidance on its bulk sensitive data rule, which became effective earlier this month. The “Data Security Program” restricts certain transactions that would allow access to large volumes of data on U.S. citizens. Details, FAQ and guidance inside.
Last week, the DOJ updated its guidance on the Foreign Corrupt Practices Act to more closely align it with President Trump’s “America First” agenda. Among other things, the new guidance directs prosecutors to prioritize national security when considering whether to initiate enforcement.
Last week, the Department of Justice released a flurry of memos that detail how it will prioritize the investigation and prosecution of white collar crimes. The policy pronouncements focus on a number of “high-impact areas,” and cover monitors, self disclosure, whistleblower awards, and more.
Export control compliance is increasingly a concern for banks and financial institutions, not just exporters. So, for the first time, the Bureau of Industry and Security has provided detailed guidance for what controls it expects financial institutions to employ. Details, guidance inside.
The Department of Defense has changed the way it vets parties working on government contracts. The new policy extends to those working on unclassified contracts as well; previously it just applied to classified contracts. Details and a downloadable version of the new DoD instructions are inside.
New guidance from CFIUS has clarified that the Committee may request follow-up information on all foreign investors that are parties to a particular transaction, whether they’re involved directly or indirectly. That includes limited partners in venture capital or private equity funds. Details are inside.
The latest FAQ from CFIUS provides some details on “springing rights,” such as information rights that might only become effective after CFIUS approves a transaction. According to the Committee, those provisions may no longer be okay for mandatory filings. Details and the actual guidance are inside.