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February 1, 2021 For the third consecutive year, following the publication of Gibson Dunn’s ninth annual U.S. Cybersecurity and Data Privacy Outlook and Review on Data Privacy Day, we offer this separate International Outlook and Review. Like many recent years, 2020 saw significant developments in the evolution of the data protection and cybersecurity landscape in the European Union (“ EU”): CJEU” or “ Court”) struck down as legally invalid the EU-U.S. Privacy Shield, on which some companies relied to transfer personal data from the EU to the U.S.  While companies are turning to ...

ACR”) entered into force, also known as “GWB Digitalization Act” (the “ Amendment”). With the passing of the Amendment[1], Germany is setting the pace for an ambitious goal: the regulation of digital platforms. As noted during the parliamentary discussion[2], the new provisions are specifically designed to provide the German Federal Cartel Office ( Bundeskartellamt) with an efficient instrument against alleged “Wild West methods” in the digital sector to keep digital markets open. The Amendment also introduces a number of other changes to the German Competition Act concerning, ...

Recovering from a relatively slow start to the year, due in no small part to the global pandemic, the U.S. Foreign Corrupt Practices Act (“FCPA”) Units of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) closed the year with a bang. With 32 combined FCPA enforcement actions, 51 total cases including ancillary enforcement, and a record-setting $2.78 billion in corporate fines and penalties (plus billions more collected by foreign regulators), 2020 marks another robust year in the annals of FCPA enforcement. This client update provides an overvie...

December 18, 2020 On December 14, 2020, the United States imposed sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), the country’s defense procurement agency, and four senior officials at the agency, for knowingly engaging in a “significant transaction” with Rosoboronexport (“ROE”), Russia’s main arms export entity, in procuring the S-400 surface-to-air missile system. These measures were a long-time coming—under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) of 2017, the President has been required...