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New Data Center Validated End User Program Creates Pathway to Export Advanced U.S. Technology; Rigorous Review and Vetting...

Effective October 2, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), amended the Export Administration Regulations (EAR), 15 C.F.R. Parts 730 – 774, to expand the Validated End User (VEU)...more

Department of Homeland Security Proposes Rule for Reporting of Cyber Incidents

On April 4, 2024, the Cybersecurity and Infrastructure Security Agency (“CISA”) published for public comment a long-awaited proposed rule to implement the Cyber Incident Reporting for Critical Infrastructure Act of 2022...more

FBI and DOJ Offer Guidance on SEC Cybersecurity Incident Disclosure Rules

On December 18, 2023, new cybersecurity rules adopted by the U.S. Securities and Exchange Commission (SEC) became effective. Among other things, those rules require SEC registrants to disclose certain information about...more

President Biden’s National Cybersecurity Strategy Unveiled

On March 2, 2023, the White House Office of the National Cyber Director released the National Cybersecurity Strategy (the “Strategy”). While the Strategy carries no legal force in and of itself, it sets forth a bold roadmap...more

New Cyber Incident Reporting Law Covering Range of Critical Infrastructure Companies

On March 15, 2022, President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (the “Act”) as part of an omnibus appropriations bill. The Act compels “covered entities” — companies in...more

DOJ Announces Civil CyberFraud Initiative to Use False Claims Act to Enforce Cybersecurity Standards in Government Contracts

On October 6, the Deputy Attorney General (“DAG”) announced a new Department of Justice (“DOJ”) Civil Cyber-Fraud Initiative – an effort that pulls together attorneys and experts across DOJ focused on fraud enforcement,...more

DOJ Announces Civil Cyber-Fraud Initiative to Use False Claims Act to Enforce Cybersecurity Standards in Government Contracts

FCA ENFORCEMENT SHIFT - On October 6, the Deputy Attorney General (“DAG”) announced a new Department of Justice (“DOJ”) Civil Cyber-Fraud Initiative – an effort that pulls together attorneys and experts across DOJ focused on...more

The Department of Labor Issues its First Cybersecurity Guidance for Plan Sponsors, Fiduciaries and Service Providers

It’s been, as the song goes, a long, long time coming. In April, the Department of Labor issued its first ever formal cybersecurity guidance for retirement plan sponsors and retirement plan fiduciaries, and for the service...more

Virtual Currency as a Threat to National Security?

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

CFIUS Proposes New Rules Scrutinizing Foreign Investment

On September 17, 2019, the Committee on Foreign Investment in the United States (“CFIUS”) published two Proposed Rules to implement most of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). CFIUS is an...more

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