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Attention Security Managers and FSOs

Client Alert | 1 min read | 07.05.17

The Office of the Director of National Intelligence has issued Security Executive Agency Directive 3, and increased reporting requirements for executive branch employees and contractors with access to classified information or who hold sensitive positions. Among other things, covered individuals must report non-work related foreign travel to their local security office for advance approval and security briefing, and any unplanned day trips into Mexico or Canada must be reported within five days of returning to the U.S. Additionally, the directive requires that all individuals with access to classified information report any continuing association with foreign nationals with whom they share “affection, personal obligation or intimate contact,” as well as any contact with foreign nationals that results in the sharing of personal information.

Insights

Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....