Implementation of Foreign Investment and National Security Act

Davis Polk & Wardwell attorneys Margaret M. Ayres and Jeanine P. McGuinness prepared a memorandum entitled FINSA Final Regulations (.pdf) discussing the final regulations issued by the U.S. Department of the Treasury to implement the Foreign Investment and National Security Act of 2007. That law amended the 1988 “Exon-Florio” statute and made significant changes to … Read more »

Leading Corporate Integrity: Defining the Role of the Chief Ethics and Compliance Officer

Fellows of the Ethics Resource Center, Business Roundtable Institute for Corporate Ethics, the Ethics and Compliance Officer Association, the Open Compliance and Ethics Group (OCEG), and the Society of Corporate Compliance & Ethics put together Leading Corporate Integrity: Defining the Role of the Chief Ethics and Compliance Officer (pdf). Senior corporate executives are under great … Read more »

Specially Designated Nationals and Blocked Persons List Updated

Here are the new bad guys on the OFAC’s Specially Designated Nationals list: AW-MOHAMED, Ahmed Abdi (a.k.a. ABUZUBAIR, Muktar Abdulrahim; a.k.a. AW MOHAMMED, Ahmed Abdi; a.k.a. “ABU ZUBEYR”; a.k.a. “GODANE”; a.k.a. “GODANI”; a.k.a. “SHAYKH MUKHTAR”); DOB 10 Jul 1977; POB Hargeysa, Somalia; nationality Somalia (individual) [SDGT] EL HABHAB, Redouane (a.k.a. “ABDELRAHMAN”), Iltisstrasse 58, Kiel 24143, … Read more »

Violation Reporting under the Federal Acquisition Regulations

Government contractors have new reporting requirements under the Federal Acquisition Regulations. Beginning December 12, 2008, contractors and subcontractors performing federal contracts—irrespective of monetary value or duration—will be legally obligated to disclose to the relevant federal agency’s Office of Inspector General credible evidence of federal criminal law violations involving fraud, conflict of interest, bribery or gratuities; … Read more »

Update to the Federal Acquisition Regulations

The Civilian Agency Acquisition Council and the Defense Acquisition Regulations Council (Councils) have agreed on a final rule amending the Federal Acquisition Regulation (FAR) to amplify the requirements for a contractor code of business ethics and conduct, an internal control system, and disclosure to the Government of certain violations of criminal law, violations of the … Read more »