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WilmerHale

DOJ Issues Guidance for New Data Security Program

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On April 8, the Department of Justice’s (“DOJ’s”) final rule on Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Rule”) formally took effect. ...more

Troutman Pepper Locke

DOJ’s Latest Guidance on the Data Security Program – What’s New?

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The new Department of Justice (DOJ) Data Security Program (DSP) took effect on April 8....more

Proskauer Rose LLP

The DOJ’s Final Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered...

Proskauer Rose LLP on

On December 27, 2024, the Department of Justice (the “DOJ”) issued its final rule (the “Rule”) carrying out Executive Order 14117 “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

Klein Moynihan Turco LLP

Daniel’s Law Update

Our readers may recall a prior piece in which we discussed a New Jersey federal district court (“District Court”) decision denying constitutionality-related challenges to a New Jersey privacy law known as Daniel’s Law. Below,...more

Venable LLP

DOJ Issues Final Rule on Bulk Sensitive Personal Data

Venable LLP on

On January 8, 2025, the Department of Justice (DOJ) published in the Federal Register a Final Rule, "Preventing Access to U.S. Sensitive Personal Data and Government Related Data by Countries of Concern or Covered Persons,"...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

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On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fortifying US Data: Proposed Rule Would Establish a New Regime To Restrict or Prohibit Certain Data Transactions With Countries of...

On October 29, 2024, the U.S. Department of Justice (DOJ) published a proposed rule (Proposed Rule) that would restrict or prohibit certain transactions with China, Russia and other countries of concern involving U.S....more

Orrick, Herrington & Sutcliffe LLP

CFPB spars with large tech company on supervision

On December 6, the CFPB announced its decision and order to supervise a large tech company, designating it as a “covered person” which allegedly engaged in financial conduct that may have posed risks to consumers. Unlike an...more

Benesch

DOJ Proposes Rules Limiting Transfer of Sensitive Data to Countries and Individuals

Benesch on

Pursuant to President Biden’s March Executive Order, the DOJ has proposed new rules limiting the transfer of certain categories of data to “countries of concern” or “covered persons”....more

Fenwick & West LLP

Compliance Deadline Approaches for New Regs Targeting U.S. Investment in Chinese AI, Semiconductors, Quantum Tech

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On November 15, the U.S. Department of the Treasury published final regulations to implement its long-awaited “Outbound Investment” Security Program, which the Biden Administration originally introduced in August 2023 under...more

Holland & Knight LLP

CFPB Finalizes New Federal Supervision of Certain Providers of Digital Wallets, Payment Apps

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The Consumer Financial Protection Bureau (CFPB) on Nov. 21, 2024, issued a final rule to supervise larger nonbank companies that offer "general-use digital consumer payment applications" such as digital wallets, payment apps...more

Latham & Watkins LLP

Final US Outbound Investment Rules to Be Effective January 2, 2025: Key Questions Answered

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The Final Rule prohibits or requires notification of certain US investments in Chinese and Chinese-controlled entities involved in semiconductors, quantum information technologies, and artificial intelligence....more

Butler Snow LLP

Proposed Rule Published Restricting Data Sharing with China, Russia, Iran, North Korea, Cuba, and Venezuela

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The US Department of Justice issued a Notice of Proposed Rule Making (NPRM) October 21, 2024 that, if finalized, will prohibit or restrict a significant amount of international data sharing with countries of concern,...more

WilmerHale

DOJ Issues NPRM Regarding Sensitive Data Transfers

WilmerHale on

With the publication of a recent Notice of Proposed Rulemaking (NPRM), the Department of Justice National Security Division will soon become an important new regulator of transactions involving the transfer of sensitive U.S....more

Morgan Lewis

Amended Daniel’s Law Sparks Litigation and Business Implications

Morgan Lewis on

Daniel’s Law, a New Jersey privacy statute aimed at protecting public officials’ personal information from being disclosed online, has been on the books since 2020. But a slew of amendments made to Daniel’s Law in 2023 that...more

Baker Botts L.L.P.

U.S. Government Proposes Reporting Requirements on the Development, Acquisition or Possession of Advanced AI Models and Large...

Baker Botts L.L.P. on

The Department of Commerce’s Bureau of Industry and Security’s (“BIS”) newly proposed rule on advanced artificial intelligence (“AI”) models and computing clusters will require developers and owners of powerful AI models and...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Presidential Election Campaign Donations May Trigger Investment Adviser “Pay to Play” Rule

Overview: Investment advisers that seek to manage public money need to consider the SEC’s “pay to play” rule, which restricts election-related contributions by the firms or their “covered associates” to elected state...more

Eversheds Sutherland (US) LLP

Treasury releases proposed Outbound Investment Security Program rules

On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more

Troutman Pepper Locke

Contract Terms and Conditions Come Under CFPB Scrutiny

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The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a circular warning covered persons that including unlawful or unenforceable terms and conditions in consumer contracts can violate the prohibition on...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Third Attempt: Banking Agencies Revive Incentive-Based Compensation Rules for Financial Institutions

The Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and the National Credit Union Administration (NCUA) recently re-proposed rules...more

Troutman Pepper Locke

Proposed Amendments to New Jersey’s Daniel’s Law

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On May 13, Senator Joseph P. Cryan (D) introduced an amendment to New Jersey’s Daniel’s Law, which would broaden the law’s coverage. An identical amendment was introduced by Assemblywoman Annette Quijano (D) in the Assembly...more

Dechert LLP

Third Circuit Holds Securitization Trusts Are “Covered Persons” Under CFPA

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A long-awaited Third Circuit decision held that securitization trusts holding student loans are “covered persons” subject to the CFPB’s enforcement and investigative powers because they “engage” in offering or providing...more

Hudson Cook, LLP

CFPB Bites of the Month - April 2024 - Won't Get Fooled Again, CFPB

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In this month's article, we share some of our top "bites" covered during the April 2024 webinar....more

Hudson Cook, LLP

CFPB Updates Supervision Designation Procedures for Nonbanks Posing Risks

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On April 16, 2024, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") issued a rule to update its procedures for designating nonbank covered persons for supervision. Section 1024(a)(1)(C) of the Consumer Financial...more

White & Case LLP

Recent Proliferation of Lawsuits Under New Jersey’s Daniel’s Law

White & Case LLP on

Plaintiffs' attorneys recently have filed a series of lawsuits in New Jersey, seeking damages based on alleged violations of Daniel's Law (N.J. Stat. § 56:8-166.1). The suits allege that various website operators have...more

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