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Risk Assessment Cybersecurity Disclosure Requirements

Skadden, Arps, Slate, Meagher & Flom LLP

The Informed Board - Winter 2024

The oversight obligations of boards continue to expand. Recent enforcement actions and new laws in areas such as cybersecurity, artificial intelligence and supply chains create new challenges for boards, as we explain in this...more

Mintz

EnforceMintz — 2023 Brings Uptick in Cybersecurity Enforcement, Insight Into Potential Risks

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After the Department of Justice (“DOJ”) announced its Civil Cyber-Fraud Initiative in October 2021, many in the False Claims Act (“FCA”) bar expected an onslaught of enforcement actions and qui tam cases. The initiative...more

Smith Anderson

Public Companies Update: Reminders for the 2024 Form 10-K and Proxy Statement Filing Season

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In this Client Alert, we highlight key considerations public companies should keep in mind when preparing their upcoming annual reports on Form 10-K and proxy statements, including rule changes, recent guidance and reporting...more

Paul Hastings LLP

Public Company Watch: December 2023

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In the December Public Company Watch, we cover key issues impacting public companies, including a preview of the SEC’s latest regulatory agenda, an update regarding the Fifth Circuit vacating the SEC’s share repurchase rules,...more

Akin Gump Strauss Hauer & Feld LLP

SEC Turning Up the Heat: SolarWinds and Its CISO Charged with Fraud Regarding Cyber-related Disclosures

Key Takeaways - With the SolarWinds enforcement action, the SEC continues to ratchet up its enforcement against companies that fail to properly disclose their cybersecurity incidents and risks. By naming the SolarWinds CISO...more

K&L Gates LLP

President Biden Issues Wide-Ranging Executive Order on Artificial Intelligence

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On 30 October 2023, President Biden issued a long-awaited executive order (EO) on artificial intelligence (AI). The EO itself is available here, and a one-page fact sheet issued by the White House is available here. The...more

Latham & Watkins LLP

Recent Developments for Directors - October 2023 Edition

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SEC Adopts Final Rules on Cybersecurity Disclosures - The SEC has adopted rules requiring companies to provide disclosure within four business days of determining that a material cybersecurity incident has occurred, and...more

Health Care Compliance Association (HCCA)

11 Years After First Disclosure, L.A. Care Pays $1.3M, Says ‘Processing Errors’ Caused Breaches

Report on Patient Privacy 23, no. 10 (October, 2023) By 2016, it should have been clear to HIPAA covered entities that a security risk analysis—and corresponding risk management plan—were compliance basics. Yet, a new...more

Husch Blackwell LLP

SEC Heightens Issuers' Cybersecurity Disclosure Requirements

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On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted final rules regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. The final rules require...more

Paul Hastings LLP

The SEC Adopts Cybersecurity Disclosure Regime for Public Companies

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On July 26, 2023, the U.S. Securities and Exchange Commission adopted enhanced disclosure requirements regarding cybersecurity risk management, strategy, governance and incident reporting for public companies. The final rules...more

Vinson & Elkins LLP

SEC Finalizes Cybersecurity Rules for Public Companies: What's New, What's Not, and What’s Next

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On July 26, 2023, the Securities and Exchange Commission (“SEC”) voted to approve final rules governing cybersecurity disclosures of public companies (“Final Rules”). The Final Rules make meaningful changes to the current and...more

BakerHostetler

The SEC's Proposed Cybersecurity Rules: Regulatory Delay Does Not Bless Standing By

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The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more

WilmerHale

PCAOB Releases New Audit Committee Resource for 2023

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The PCAOB recently released a new Audit Committee Resource, which sets forth an updated set of questions that audit committee members may want to consider incorporating into their ongoing engagement with auditors....more

Dechert LLP

SEC Proposes New Cybersecurity Risk Management Rule for Various Market Entities

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At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted three to two to propose a new rule, form and amendments (together, “Proposed Rule”) and published an accompanying release (“Release”)...more

Ankura

How Cybersecurity Protects Valuation: Considerations for Private Equity in the Deal Lifecycle

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Cybersecurity risk applies to businesses of all sizes and across all industries – it is a risk that cannot be ignored. In particular, cybersecurity risk can no longer be ignored in the deal lifecycle...more

White & Case LLP

Cybersecurity Developments and Legal Issues

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For most large companies, a frictionless flow of information and the ability to transfer customer data, employee files, financial records and other information around the world quickly and cost-effectively is a critical...more

Pillsbury Winthrop Shaw Pittman LLP

The SEC’s Fast-Approaching Cybersecurity Overhaul for Public Companies and Regulated Entities

The SEC has nearly doubled the size of its Crypto Assets and Cyber Unit and has aggressively pursued cyber-related enforcement actions against public companies and regulated entities. In a few months the SEC will finalize...more

Smith Anderson

Reminders for the 2023 Annual Report and Proxy Season

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As public companies prepare their 2022 annual reports and 2023 proxy statements, they will need to contend with a host of new requirements and disclosure updates stemming from the current geopolitical and economic...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2022

Headlines: ..OCC Publishes Security Standards for Video Teleconferencing With Agency Staff ..CFPB Imposes Civil Penalty and Customer Refunds for Authorized-Positive Overdraft Fees ..Treasury Department Recommends...more

Porter Hedges LLP

Overview of New Cybersecurity Disclosure Rules for Public Companies

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According to the Cybersecurity & Infrastructure Security Agency, cybersecurity is the process whereby information and communications systems, and the information contained in those systems, are protected from and/or defended...more

Foley & Lardner LLP

SEC Proposes New Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

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On March 9, 2022, the U.S. Securities Exchange Commission (the Commission) announced proposed amendments to its rules regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies...more

Health Care Compliance Association (HCCA)

[Event] Research Compliance Conference - June 8th - 10th, Anaheim, CA

Hear about the latest in research compliance - Do you want to learn… - How to prepare for upcoming changes in Medicaid? - Ways to build and maintain a better research compliance work plan for your program? - How...more

White & Case LLP

Key Considerations for the 2022 Annual Reporting and Proxy Season Part I: Form 10-K Considerations

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This is Part I of a two-part series outlining key considerations from White & Case's Public Company Advisory Group for US public companies during the 2022 annual reporting and proxy season. Part I of this memo describes...more

McDermott Will & Emery

Log4j: Enforcement Risk for Public Companies

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The Apache Log4j vulnerability continues to command significant attention throughout the public and private sectors. In a recent interview, the director of the US Cybersecurity and Infrastructure Security Agency (CISA)...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - January 24th - 27th, Orlando, FL

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

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