FTC Again Delays Enforcement of Red Flags Rule
Client Alert | 1 min read | 07.30.09
The Federal Trade Commission has announced it will again extend the date for commencement of enforcement of the Red Flags Rule to prevent identity theft, moving the date back three months until November 1, 2009.
The Commission said that al though many covered entities have developed and implemented appropriate, risk-based programs since the Commission promulgated the final rule, some covered entities, particularly small businesses and entities with a low risk of identity theft, remain uncertain about their compliance obligations. To help these small and low risk entities with compliance, the Commission staff will shortly make available additional resources and guidance at the FTC's Red Flags Rule website.
In the meantime, groups representing physicians, lawyers and others treated as "creditors" under the Red Flags Rule are continuing to seek legislation or court relief against the rule.
Insights
Client Alert | 8 min read | 10.01.25
On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.
Client Alert | 2 min read | 09.30.25
CARB Issues Preliminary List of Entities Covered by California Climate Disclosure Laws
Client Alert | 10 min read | 09.30.25
Client Alert | 7 min read | 09.29.25
White House Seeks Industry Input on Laws and Rules that Hinder AI Development
