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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 | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....