On June 24, 2024, the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued five new Compliance and Disclosure Interpretations (“C&DIs”) related to the disclosure of “material”...more
7/11/2024
/ Corporate Governance ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Disclosure Requirements ,
Form 8-K ,
Publicly-Traded Companies ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
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)
On June 13, 2023, the Securities and Exchange Commission (“SEC”) published its Spring 2023 rulemaking agenda that delayed finalizing the proposed Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure...more
The Indian Computer Emergency Response Team (“CERT-In”) issued Directions on April 28, 2022 “to strengthen the cybersecurity in the country” and that has significant implications for the cybersecurity landscape. Effective...more
The Strengthening American Cybersecurity Act of 2022, a bill that narrowly failed to become law last year, was passed in the Senate on Tuesday, March 1 as a package of cybersecurity measures that would require operators of...more
3/4/2022
/ Cyber Attacks ,
Cyber Incident Reporting ,
Cyber Threats ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Breach ,
Data Breach Plans ,
Data Privacy ,
Data Protection ,
Data Security ,
Popular ,
Reporting Requirements
Selected Developments in U.S. Law - SEC Proposed Rule Will Require Private Funds to Report Certain Cyber Events On January 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules to enhance hedge fund...more
2/9/2022
/ China ,
Cyber Incident Reporting ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Breach ,
Data Privacy ,
Data Security ,
Data Subject Access Requests ,
Federal Trade Commission (FTC) ,
General Data Protection Regulation (GDPR) ,
International Data Transfers ,
Malware ,
Multi-Factor Authentication ,
NYDFS ,
Personal Data ,
Popular ,
Ransomware ,
Reporting Requirements ,
Russia ,
Ukraine
As an update to prior coverage of the FTC’s final revisions to the Gramm-Leach-Bliley Safeguards Rule (Final Rule), following its publication in the Federal Register on December 9, 2021, the Final Rule now will take effect on...more
On December 7, 2021, the House of Representatives passed the National Defense Authorization Act for Fiscal Year 2022 (NDAA), which notably excluded any cybersecurity incident reporting requirements. In September, the House...more
On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of...more
The New York Department of Financial Services (NYDFS) issued new guidance this week intended to assist organizations in thwarting ransomware attacks. The guidance clarifies the NYDFS’ expectation that NYDFS-regulated...more
Selected Developments in U.S. Law - Fifth Circuit Decision Raises Cyber Enforcement Complications for the U.S. Department of Health and Human Services As the Biden Administration begins detailing its regulatory and...more
2/18/2021
/ Attorney-Client Privilege ,
Biden Administration ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Security ,
Department of Health and Human Services (HHS) ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
State Privacy Laws ,
Work-Product Doctrine
On December 18, 2020, federal financial regulatory agencies jointly announced a proposed rule that would impose new and expanded reporting requirements on supervised banking organizations that experience a “computer-security...more
Frameworks requiring breach notifications of various kinds significantly expanded in scope in 2016 at both the state and federal levels. However, at least in the U.S., some of the new federal requirements may not be in place...more
1/9/2017
/ Breach Notification Rule ,
Customer Proprietary Network Information (CPNI) ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Department of Financial Services ,
EU ,
FCC ,
Financial Institutions ,
Food and Drug Administration (FDA) ,
General Data Protection Regulation (GDPR) ,
Personal Data ,
Popular ,
Reporting Requirements ,
Safe Harbors