Last week, at a gathering of the nation’s top white collar criminal defense attorneys in Miami, Florida, Deputy Attorney General Lisa Monaco announced material changes to the way the Department of Justice will investigate,...more
In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more
10/27/2021
/ Anti-Money Laundering ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Virtual Currency
On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more
On Tuesday, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued an updated advisory warning all ransomware victims that if they succumb to ransomware demands and pay foreign actors who are...more
9/24/2021
/ Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
FBI ,
Guidance Update ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Sanctions ,
SDN List ,
Strict Liability ,
U.S. Treasury
Last Friday, China passed the world’s harshest data privacy law, threatening violators with fines of up to 50 million Yuan (or about $7.7 million at the time of publication) or 5% of annual revenue. The Personal Information...more
On the heels of the First American enforcement action and settlement, this week, the SEC announced a settlement with Pearson plc in connection with a 2018 cyber breach. The SEC disclosed that Pearson, a London-based...more
Data privacy lawyers and cyber security incident response professionals are losing sleep over the growing number of federal courts ordering disclosure of post-data breach forensic reports. Following the decisions in Capital...more
As cyberattacks continue to attract greater attention, the SEC has taken an additional step in its efforts to bring enforcement actions related to cyber disclosures. On June 14, the SEC announced settled charges against a...more
6/22/2021
/ Cease and Desist Orders ,
Cyber Attacks ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fines ,
Internal Controls ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Security Breach
On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more
6/10/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
China ,
Corporate Transparency Act ,
Cybersecurity ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC)
The cyber landscape is changing once again, in terms of impact, policy and potential exposure. In the wake of the Colonial Pipeline hack, the Biden administration released a long-awaited Executive Order intended to strengthen...more
5/18/2021
/ Biden Administration ,
Critical Infrastructure Sectors ,
Cyber Attacks ,
Cybersecurity ,
Department of Energy (DOE) ,
Energy Regulatory Commission ,
Enforcement ,
Executive Orders ,
Federal Contractors ,
Hackers ,
National Security ,
Pipelines ,
Popular ,
Proposed Regulation ,
Regulatory Oversight