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 | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
