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Corporate Client Compliance Alert

On May 25, 2018, US Companies that do business in Europe will be subject to the General Data Protection Regulation (GDRP).

This new law applies throughout the EU (including the UK).  Its broad provisions regarding extraterritoriality and global data access, treatment and transmission means that all US and foreign companies which have business relationships and contacts with any EU member state will be affected, directly or indirectly.

Partner Ted Banks Featured on Video Interview with Eric Morehead of NYSE

“Partner Ted Banks was featured in an interview with Eric Morehead of NYSE Governance Services on “The Road Ahead for Corporate Compliance.”  In this video, he discusses the role of compliance and ethics programs in guiding companies and individuals to “do the right thing,” how an external compliance monitor can really help a company, and why a change in the Antitrust Division’s approach to compliances programs appropriate.

The Biggest Compliance Mistake That Lawyers Make

Partner Ted Banks, along with Eric Hinton, Chief Ethics & Compliance Officer at 7-Eleven, Inc., published an article, ‘The Biggest Compliance Mistake That Lawyers Make,’ in the In-House Access blog of the Association of Corporate Counsel.  The article discusses ways to make certain that compliance programs actually reach employees by focusing on the employee, rather than trying to re-teach law school.  If you have any questions about compliance programs, contact Ted Banks at

Using Personal Email at Work

Nearly everyone who has email at work uses it occasionally for personal correspondence.  Similarly, many people use their personal email accounts for business communications. Hillary Clinton used a private server for her email while Secretary of State so that she could continue to control her personal email.  What are the implications of using your work email for personal correspondence, or your personal email for work correspondence?

Does the Wall Street Journal know anything about compliance?

A few days ago, the Wall Street Journal published an editorial about the government’s case against Apple for price fixing of e-books.  Apple lost the case, and the court appointed a monitor to ensure compliance with the court’s decision and the antitrust laws.  But even granting the publication a little leeway for editorial writing, a few things about that editorial struck me that just didn't sit right.  (Disclaimer: I am a compliance monitor for the FTC and the Canada Competition Bureau, and these opinions are my own.

So maybe the Robinson-Patman Act isn’t dead after all.


Woodman’s Food Market is a chain of warehouse-style grocery stores in Wisconsin.  As such, its sales strategy was similar to that employed by Costco and Sam’s Club: the ability to purchase groceries at lower prices by purchasing in large size containers.  However, Woodman’s did not charge a membership fee as a prerequisite to shopping at its stores.

Personal liability for compliance officers: recent government enforcement and lessons learned

On December 2014, a 57-page complaint filed by the U.S. Attorney in Manhattan sought to impose personal liability on the former compliance officer for MoneyGram International, Thomas Haider. It alleges that he willfully or recklessly failed to stop money laundering activities. The complaint seeks a fine of $1 million and would bar Haider from working in financial services.