<i>' ' [A]lthough nothing is off the table when you voluntarily disclose, I can tell you in unequivocal terms that you will get a real benefit ' '</i> Despite these heartening words by Assistant U.S. Attorney General Alice S. Fisher at a recent conference on the Foreign Corrupt Practices Act (FCPA), an attorney representing a corporation cannot recommend voluntary disclosure of potentially criminal FCPA activities without weighing the promise of a 'real benefit' against the very real risks.
Pamela Sawhney' ' [A]lthough nothing is off the table when you voluntarily disclose, I can tell you in unequivocal terms that you will get a real benefit ' '
Despite these heartening words by Assistant U.S. Attorney General Alice S. Fisher at a recent conference on the Foreign Corrupt Practices Act (FCPA), an attorney representing a corporation cannot recommend voluntary disclosure of potentially criminal FCPA activities without weighing the promise of a 'real benefit' against the very real risks.
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New York is one of the first states to adopt laws to regulate artificial intelligence use in advertising and to strengthen post-mortem publicity rights regarding AI-generated replicas and “synthetic performers.” Given the state’s role as a bellwether for consumer-protection and advertising regulation, these new laws, combined with the state’s broader AI legislative framework, represent a shift toward transparency, consent and accountability.
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A recent decision from the U.S. District Court for the Southern District of New York (SDNY), United States v. Heppner, has generated outsized commentary suggesting that the use of generative AI tools may jeopardize attorney-client privilege. A closer reading shows something far less dramatic.
