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The Federal Trade Commission in January provided more details on its proposed changes to the Children's Online Privacy Protection Rule, underscoring the need for online operators to review and prepare to update their policies and procedures.
The rule — created by the FTC in response to Congress' passage of the Children's Online Protection Act of 1998 — currently requires verifiable parental consent before "any collection, use, or disclosure" of personal information from children. The first version of the rule went into effect in 2000, and the last update was in 2013.
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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.
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.
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.
This article explores legal developments over the past year that may impact compliance officer personal liability.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.