In response to the OECD Working Group on Bribery’s (WGB) call for comments from stakeholders as part of its upcoming review of the 2009 OECD Anti-Bribery Recommendation, TRACE has submitted its overview of the significant challenges the new EU data protection legislation poses to corporate anti-bribery compliance programs. … Continue Reading
We’re based in the United States, so how does the GDPR concern us?
GDPR’s Article 3(1) ties the GDPR’s territorial scope to being established in the EU, while Article 3(2)(a) extends the GDPR’s reach to those non-EU companies that offer products or services to individuals in the EU.… Continue Reading
It has been over three months since the EU General Data Protection Regulation (GDPR) went into effect. The sky hasn’t fallen, and we are still here. We at TRACE now wear a t-shirt saying “I survived the GDPR” and see the humor in GDPR jokes and online memes.… Continue Reading
On May 24, I wrote a post for the FCPA Blog about TRACE’s concerns that Article 10 of the new EU General Data Protection Regulation (GDPR) presents an obstacle to anti-bribery due diligence of third parties, and how we have advocated for an EU-wide, or at least a national-level, solution.… Continue Reading
We at TRACE have written extensively about our concern that Article 10 of the new EU General Data Protection Regulation (GDPR) presents an obstacle to anti-bribery due diligence of third parties, which is a necessary component of any corporate compliance program under the FCPA and other transnational anti-corruption laws (here, here, here, and here).… Continue Reading