Following a year of high-profile data breaches, the Securities and Exchange Commission (SEC) announced on January 13, 2015 that, for the second consecutive year, its Office of Compliance Inspections and Examinations (OCIE)...more
President Obama issued an Executive Order (the “Order”) on April 1, 2015 that authorizes financial sanctions against certain “persons” (including both individuals and entities) designated by the Treasury Secretary to be...more
The Securities and Exchange Commission’s (the “SEC” or the “Commission”) Office of Compliance Inspections and Examinations (“OCIE”) announced in an April 15, 2014 Risk Alert (the “Alert”) that it will be conducting...more
Executive Summary: Federal Trade Commission v. Wyndham Worldwide Corp.
A U.S. District Court has ruled this week that the Federal Trade Commission (FTC) has authority under Section 5 of the FTC Act to bring enforcement...more
The SEC and CFTC recently issued joint Identity Theft Red Flags Rules (the “Rules”), which are rules and guidelines requiring certain financial institutions worldwide to adopt comprehensive data security programs to detect...more
With the rise in targeted, sophisticated, malicious attacks on corporate America’s electronic infrastructure, companies are increasingly focused on their cybersecurity disclosure obligations. There is a growing concern that...more
The Obama Administration has long expressed concerns about the vulnerability of America’s critical infrastructure to cyber-attack. On February 12, 2012, the day of the President’s State of the Union address, the...more