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Cyberattacks on U.S. energy infrastructure have been on the rise in 2024. According to the 2024 Thales Data Threat Report, 42% of critical infrastructure companies, including those in the energy sector, suffered data breaches...more
In May 2023, Florida became among the first states to limit select persons from "foreign countries of concern" from directly or indirectly owning, having a controlling interest in or acquiring an interest in Florida real...more
As discussed in our previous blog post, the Cybersecurity and Infrastructure Security Agency (CISA) is proposing a significant new rule to bolster the nation’s cyber defenses through mandatory incident reporting. While...more
Cyber incidents involving critical infrastructure pose a serious risk to the US. In March 2024, the Environmental Protection Agency and the National Security Advisor warned state governors about potential attacks on drinking...more
What is a CFIUS filing, when should it be made, and what happens if a party fails to file? In passing the Foreign Investment and Risk Review Modernization Act in 2018, Congress provided CFIUS with increased resources to...more
By now, companies that collect, process, and store the personal data of consumers are used to a fast pace of state privacy and cybersecurity legal activity. This year, companies should also expect increased activity from...more
On April 15, 2024, the secretary of the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or Committee), published a notice of proposed rulemaking (Proposed Rule) to...more
April 2024 On April 4, 2024, the U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (“CISA”) published a 447-page Notice of Proposed Rulemaking (“Proposed Rules”) in accordance with the...more
On April 4, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published its much-anticipated Notice of Proposed Rule Making for the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA)....more
CISA's proposed rules will require organizations operating in U.S. critical infrastructure sectors to report cyber incidents within 72 hours and ransom payments within 24 hours. ...more
In 2025, new federal reporting requirements will require hundreds of thousands of organizations to report cyber incidents within hours of discovery to the United States Government, marking a significant impact on how...more
On March 15, 2022, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 was signed into law. Generally, CIRCIA requires “covered entities,” defined as entities in certain critical infrastructure sectors, to...more
A sweeping array of businesses are another step closer to requirements to report cybersecurity incidents and ransomware payments to the federal government. On April 4, 2024, the U.S. Department of Homeland Security's (DHS)...more
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA), an operational component of the Department of Homeland Security (DHS), posted for public inspection its long-anticipated notice of proposed...more
On March 27, 2024, the Cybersecurity & Infrastructure Security Agency (CISA) within the US Department of Homeland Security released a much-anticipated notice of proposed rulemaking (NPRM) to implement the Cyber Incident...more
The federal Cybersecurity and Infrastructure Security Agency (CISA) released a draft of its proposed rule detailing how covered entities operating in critical infrastructure sectors report cyberattacks and ransomware payments...more
On November 7, 2023, the Consumer Finance Protection Bureau (“CFPB”) proposed a new rule that calls for federal regulatory oversight of large nonbank companies that offer digital wallets and payment apps to consumers. The...more
On September 20, 2023, the Florida Department of Commerce (“DOC”) (formerly known as the Florida Department of Economic Opportunity) released its initial set of proposed Rules for implementing SB 264 (Chapter No. 2023-33,...more
Last month, the Committee on Foreign Investment in the United States (CFIUS) issued a proposed rule that could restrict foreign investment in real estate located near certain military bases. As background, CFIUS is made up...more
In our recent article Amid TikTok Tensions, CFIUS Signals Increased Enforcement and Other Updates, we discussed updates from the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) primarily with...more
On May 5, 2023, the U.S. Department of the Treasury, in its role as the chair of the Committee on Foreign Investment in the United States (“CFIUS”), issued a proposed rule in the Federal Register that would (i) expand by...more
President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The background and contours of CIRCIA are discussed in a previous update. CIRCIA authorizes and...more
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
In the wake of Russia’s invasion of Ukraine, and amid growing concerns regarding the threat of increased cyberattacks targeting infrastructure and other critical industries, there has been a flurry of federal activity to...more
President Biden recently signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 as a part of a larger omnibus appropriations bill. The new law sets out mandatory reporting requirements for...more