News & Analysis as of

Department of Justice (DOJ) Incident Response Plans

Thomas Fox - Compliance Evangelist

Internal Control Lessons from Star Trek: The Doomsday Machine

Last month, I wrote a blog post on the tone at the top, exemplified in the Star Trek, the Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a...more

American Conference Institute (ACI)

[Event] 15th Annual Advanced Forum on Managed Care Disputes and Litigation - May 2nd - 3rd, Chicago, IL

ACI’s Advanced Forum on Managed Care Disputes and Litigation offers an unparalleled learning experience, specifically designed for the MCO legal community. Attend and develop winning legal strategies and business best...more

Paul Hastings LLP

SEC Speech on Cybersecurity Disclosure

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On December 14, 2023, Erik Gerding, Director, Division of Corporation Finance at the Securities and Exchange Commission (“SEC”) gave a speech on the SEC’s final rules (the “Final Rule(s)”) regarding cybersecurity risk...more

Skadden, Arps, Slate, Meagher & Flom LLP

FBI, DOJ and SEC Publish Guidance on Requesting Delayed Reporting of Material Cyber Incidents on Form 8-K: Takeaways for CISOs and...

The U.S. Securities and Exchange Commission (SEC) adopted final rules in 2023 that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and incident reporting by...more

Bass, Berry & Sims PLC

Cyber Incident Reporting May Be “Material” for Federal Contractors

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Last month, the Federal Acquisition Regulatory Council proposed new cybersecurity and incident reporting regulations for federal contractors on behalf of the Department of Defense (DoD), the General Services Administration...more

King & Spalding

Proposed FAR Revisions Aim to Standardize Cybersecurity Requirements Across Agencies and Add Incident Reporting Obligations for...

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On October 3, the Department of Defense, General Services Administration, and the National Aeronautics and Space Administration published two sets of proposed revisions to the Federal Acquisition Regulation (“FAR”) pertaining...more

Health Care Compliance Association (HCCA)

Privacy Briefs: October 2023

Report on Patient Privacy 23, no. 10 (October, 2023) Kaiser Foundation Health Plan Inc. and Kaiser Foundation Hospitals will pay California $49 million to resolve allegations that they unlawfully disposed of hazardous waste,...more

Snell & Wilmer

DOJ Establishes New "Disruptive Technology Strike Force" to Address Sharing of Sharing Sensitive Technology with Adversaries

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In February 2023, the Department of Justice (DOJ) announced the creation of the Disruptive Technology Strike Force (strike force) in conjunction with the Department of Commerce to protect against the illegal export of U.S....more

American Conference Institute (ACI)

[Event] 12th Summit on Anti-Corruption Brazil - May 24th - 25th, Sao Paulo, SP, Brazil

Hosted by American Conference Institute, the 12th Summit on Anti-Corruption Brazil returns for another exciting year with a newly revamped, truly interactive networking and benchmarking experience. In addition to critical...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

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The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

BakerHostetler

Former Uber Chief Security Officer Convicted of Federal Obstruction and Concealment Crimes in Connection with Extortionate Data...

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On October 5, 2022, a federal jury found Joseph Sullivan, Uber’s former chief security officer, guilty of obstruction of justice and misprision of a felony in connection with his role in responding to a 2016 data breach...more

WilmerHale

How Contractors Can Avoid Cybersecurity FCA Violations

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Speaking about the U.S. Department of Justice's enforcement priorities on Sept. 12 at the American Bar Association's annual Civil False Claims Act and Qui Tam Enforcement Institute conference, the principal deputy assistant...more

Balch & Bingham LLP

Business Privacy Law Lessons from Proposed Settlement with Twitter

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The Department of Justice (“DOJ”), on behalf of the Federal Trade Commission (“FTC”), filed a complaint and motion for entry of a stipulated order with the Northern District of California, which would require Twitter to pay...more

Goodwin

DOJ Announces New Initiative to Use False Claims Act to Enforce Compliance with Data Privacy and Security Laws and Contract...

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The Department of Justice recently announced the launch of its new Civil Cyber-Fraud Initiative (the “Initiative”) which intends to use the False Claims Act to pursue “cybersecurity-related fraud by government contractors and...more

Woods Rogers

New Developments in the Colonial Pipeline Attack Provide Businesses Good News – And Some Important Lessons

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It has been barely a month since we reported on the recent ransomware attack on the Colonial Pipeline Company, yet news continues to break with additional revelations about the recent attack.  What we have learned during the...more

The Volkov Law Group

Incident Data and Intra-Company Cooperation

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The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

Sheppard Mullin Richter & Hampton LLP

You Might Be an Inside Trader If…You Trade on Your Unconfirmed Suspicions of a Cybersecurity Event Prior to Its Public Revelation...

Earlier this year, the SEC released cybersecurity guidance addressing, among other things, the risk of insider trading in the event of a data breach. This risk comes in multiple forms, including the intruders trading on...more

Sheppard Mullin Richter & Hampton LLP

Crypto-Crime: The SEC and DOJ Go After BitFunder and Its BitFounder

Taking further steps into the world of cryptocurrency, two entities of the federal government recently took legal action against BitFunder, a now-defunct Bitcoin exchange, and its founder, Jon Montroll. The Securities and...more

Nutter McClennen & Fish LLP

Equifax Breach: Lessons Corporations Must Learn from Equifax’s Poor Planning and Response

Equifax’s stunning security breach and inadequate response has now claimed its most prominent victim – the CEO of Equifax, Richard Smith, announced his immediate resignation. In light of this rapid fall from grace, here...more

Stinson LLP

Emerging Trends Newsletter - Q3

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We are thrilled to bring you the third installment of Stinson Leonard Street's Emerging Trends newsletter. We are proud of the depth and breadth of experience and knowledge across our firm's 13 offices nationwide and are...more

JAMS

Health Care Matters, Summer 2016

JAMS on

Special Masters in Health Care Antitrust Merger Cases: Resolving the Conflicting Interests - One of the most challenging aspects of antitrust cases in the health care field is the rich mixture of public interest...more

King & Spalding

White House Releases Policy Directive On Cyber Incident Coordination

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On July 26, 2016, the White House approved a Presidential Policy Directive (“PPD”) on coordinating responses to cyber incidents that occur in the United States. The PPD seeks to clarify who in the federal government is...more

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

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The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

Bradley Arant Boult Cummings LLP

Data Breach Response Planning: Laying the Right Foundation

Part of Bradley Arant’s Privacy and Information Security Team’s seven-part Data Breach Toolkit Webinar Series, the “Data Breach Response Planning: Laying the Right Foundation” webinar, led by Paige Boshell and Amy Leopard,...more

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