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Franchise Disclosure Enters the Electronic Age
It was a dark and stormy Seattle day 7 years ago. The Federal Trade Commission (FTC) was in town for its workshop on the proposed revisions to the Franchise Rule (the NPR) on Nov. 6-7, 1997, to discuss whether it should allow franchisors to disclose electronically. Many people testified positively, including yours truly, and the discussion quickly turned to how to do so: floppy disks (but there were so many formats incompatible with the PCs and printers of the day), or the Internet (but there were so few prospects that had access). How much has changed!
In its Aug. 25, 2004 Staff Report, “Disclosure Requirements and Prohibitions Concerning Franchising … ” the FTC staff took the road paved that day and will recommend that the FTC permit electronic disclosure without significant qualifications.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
How AI Has Affected PR
When we consider how the use of AI affects legal PR and communications, we have to look at it as an industrywide global phenomenon. A recent online conference provided an overview of the latest AI trends in public relations, and specifically, the impact of AI on communications. Here are some of the key points and takeaways from several of the speakers, who provided current best practices, tips, concerns and case studies.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.