In the final week of the Biden Administration’s term in office, former President Biden issued two high profile executive orders that could have significant ramifications for the cybersecurity and technology industries. The...more
The recent indictment of 14 North Korean nationals for fraudulently obtaining remote IT jobs with U.S.-based companies underscores the importance of vigilant hiring practices. Our Privacy, Cyber & Data Strategy and...more
The Biden Administration’s Office for Civil Rights delivered on its promise to propose an update to the HIPAA Security Rule. Our Health Care and Privacy, Cyber & Data Strategy groups summarize key points from the new rule and...more
Our Health Care and Privacy, Cyber & Data Strategy Groups cover an upcoming proposed rule from U.S. Health and Human Services (HHS) that would formalize cybersecurity requirements and allow the Office for Civil Rights (OCR)...more
11/1/2024
/ Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Cybersecurity Framework ,
Department of Health and Human Services (HHS) ,
Electronic Protected Health Information (ePHI) ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
NIST ,
OCR ,
Ransomware ,
Risk Management
The SEC has released its Examination Priorities: Fiscal Year 2025 (“Examination Priorities”), which may be a useful roadmap to SEC-registered investment advisers, exchanges, and other entities subject to routine examination...more
10/29/2024
/ Artificial Intelligence ,
Compliance ,
Cybersecurity ,
Emerging Technologies ,
Enforcement Priorities ,
Examination Priorities ,
Investment Firms ,
Investors ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Trading Platforms
Our Consumer Protection/FTC and Privacy, Cyber & Data Strategy teams unpack Starwood Hotels’ and Marriott International’s settlements with the Federal Trade Commission and Marriott’s settlement with state attorneys general...more
10/21/2024
/ Civil Monetary Penalty ,
Cybersecurity ,
Data Breach ,
Data Security ,
Federal Trade Commission (FTC) ,
Incident Response Plans ,
Liability ,
Marriott ,
Personal Information ,
Popular ,
Regulatory Authority ,
Risk Assessment ,
Settlement
On October 16, 2024, the New York Department of Financial Services (“NYDFS”) issued an industry letter covering Cybersecurity Risks Arising from Artificial Intelligence and Strategies to Combat Related Risks (the “Industry...more
Threat actors are evolving. Our Privacy, Cyber & Data Strategy Team explains how ransomware gangs have changed their tactics and how companies can respond to the threat while navigating new scrutiny from investors and...more
2/26/2024
/ Corporate Counsel ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Data Security ,
Data Theft ,
NYDFS ,
Popular ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC)
Our Health Care and Privacy, Cyber & Data Strategy Groups delve into the Department of Health and Human Services’ extensive efforts to encourage health care organizations to better protect patients’ privacy through better...more
On January 12, 2024, the New York State Department of Financial Services (“NYDFS”) released a new Industry Letter on the use of self-service password reset (“SSPR”) services, which enable users to reset their own password...more
Our Securities and Privacy, Cyber & Data Strategy teams unpack the Department of Justice’s (DOJ) process for companies seeking to delay Form 8-K disclosures under the Securities and Exchange Commission’s (SEC) cybersecurity...more
After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s...more
Just a month before the Security and Exchange Commission’s (“SEC’s”) Material Cybersecurity Incidents Rule is set to take effect, a ransomware group has apparently taken compliance with reporting requirements into its own...more
With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more
Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more
11/13/2023
/ Chief Information Security Officer (CISO) ,
Corporate Liability ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s final changes to its cybersecurity reporting rules for public companies...more
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022....more
On October 31, 2022, the Federal Trade Commission (FTC) announced it has taken action against education technology provider Chegg Inc. (“Chegg”) for its “careless” cybersecurity practices that exposed sensitive personal...more
On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of...more
On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity...more
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s latest sweeping changes to its cybersecurity reporting rules for public...more
3/16/2022
/ Corporate Governance ,
Cyber Incident Reporting ,
Cybersecurity ,
Disclosure Requirements ,
Form 10-Q ,
Form 8-K ,
Publicly-Traded Companies ,
Regulation S-K ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act