06/16/2022
As a result, companies may now face civil liability for inadvertent breaches of financial sanctions, including where due diligence has been carried out and there was no “reasonable” cause to suspect a breach.
06/13/2022
The Commission does not recommend reliance on collective knowledge or corporate culture, but rather remains of the view that there should be an identifiable individual within senior management with the requisite culpability to attribute knowledge to the c
06/10/2022
While the Briefing is aimed at NCAs, is non-binding and not subject to any 'comply or explain' provisions, it sets out several key supervisory expectations.
06/08/2022
As discussed in our prior Legal Update, the interim rule implemented new controls on “intrusion software”2 that balanced US foreign policy and national security concerns with the need for legitimate cybersecurity transactions
06/08/2022
The package of proposals are of particular importance to very large businesses, their directors, investors and auditors.