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Enforcement Actions Security Risk Assessments

Health Care Compliance Association (HCCA)

OCR Ends Year With Settlements That Tread Old Ground, Says New Rules Are Coming—Someday

If the penultimate enforcement settlement of 2023 issued by the HHS Office for Civil Rights (OCR) sounds familiar, that’s with good reason. And the last one of the year should ring some bells, too....more

Woodruff Sawyer

CISOs Under the (Liability) Gun

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Chief information security officers (CISOs) face an increased likelihood of legal scrutiny after a significant breach. It’s par for the course for CISOs to be scrutinized when security programs don’t hold up under attack—but...more

Holland & Knight LLP

NYDFS Proposes Amendments to Cybersecurity Regulation

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The New York Department of Financial Services (NYDFS) on Nov. 9, 2022, released Proposed Amendments to its Cybersecurity Regulation. The NYDFS Cybersecurity Regulation was one of the first laws requiring companies to comply...more

BakerHostetler

New CBDC and NFT Data Released; OFAC Adds Mixer and Public Keys to SDN List; Multiple Crypto Enforcement Actions; Stablecoin Risks...

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BIS Releases Survey on CBDC Initiatives; New Crypto Products Launch - The Bank for International Settlements (BIS) recently released the results of its 2021 survey of central bank digital currencies (CBDCs). According to...more

Moore & Van Allen PLLC

SEC Announces Exam Priorities for 2022

On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations released its exam priorities for fiscal year 2022 (the “2022 Priorities”). As in years past, these exam priorities naturally...more

Holland & Knight LLP

SEC Issues First-Ever Penalties for Deficient Cybersecurity Risk Controls

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The U.S. Securities and Exchange Commission (SEC) has launched a stunning salvo across the bows of public companies with its announcement of civil monetary penalties and a cease-and-desist order against First American...more

Hinshaw & Culbertson - Consumer Crossroads

Long-Awaited DFS Cyber Enforcement Action Sees Charges Filed Against Title Insurer For Exposing Millions of Documents Containing...

After several years of anticipation, the New York State Department of Financial Services (DFS) has filed its first enforcement action under the agency's groundbreaking and first-in-the-nation 2017 cybersecurity regulation...more

Carlton Fields

Recent Cases Indicate Viability of False Claims Act Liability Connected to Federal Cybersecurity Standards

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Government contractors are no strangers to the numerous quality standards and assurances required by the government. Over the past several years, cybersecurity in federal contracting has emerged as yet another standard to...more

Health Care Compliance Association (HCCA)

Under New Settlement, Ambulance Co. Pays OCR $65K, Must Quickly Encrypt Computers

Report on Patient Privacy 20, no. 1 (January 2020) - In the waning days of 2019, the HHS Office for Civil Rights (OCR) didn’t halt the HIPAA enforcement momentum it had built up during the last quarter of the year, dinging...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 28, Number 40. News Briefs - November 2019 #2

Report on Medicare Compliance Volume 28, Number 40. (November 11, 2019) - - In a new Medicare compliance review, the HHS Office of Inspector General (OIG) said Angels Care Home Health in Salina, Kansas, didn’t comply with...more

Carlton Fields

TSA Adds New Compliance Program to Address Violations of Its Security Requirements

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On August 26, 2019, the Transportation Security Administration (TSA) enacted its new Action Plan Program. The Action Plan Program "provides an opportunity for eligible parties and TSA to discuss and reach an agreement on...more

Sunstein LLP

Twenty Years Under the Microscope: A Small Business, a Data Breach and the FTC

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James Grago has a nice business going. He runs a website called ClixSense.com that permits users to earn money by completing surveys and watching advertisements. Revenues grew from $6.7 million in 2015 to $9.1 million in...more

Fenwick & West LLP

FTC Toughening Stance on Data Security – Five Key Takeaways from Recent Consent Orders

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The Federal Trade Commission is putting more teeth into the multiyear compliance obligations of consent orders it enters into with companies to settle enforcement actions related to data breaches. The FTC recently issued a...more

Jones Day

China's New Cybersecurity Law Brings Enforcement Crackdown

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The Situation: Earlier this year, the People's Republic of China enacted its Cybersecurity Law, which granted authorities broad, explicit powers to monitor and investigate activities falling under its purview, along with the...more

Proskauer on Privacy

SEC Cybersecurity Update

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Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Orrick, Herrington & Sutcliffe LLP

Privacy, Security, Risk: What You Missed At IAPP Conference

Earlier this month, privacy and security professionals from around the globe gathered for “Privacy. Security. Risk. 2015”—the second joint conference between the International Association of Privacy Professionals and the...more

BakerHostetler

HIPAA Fine Underscores OCR’s Focus on Physician Group Compliance

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The U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) recently announced a $750,000 fine and resolution agreement, including a Corrective Action Plan (CAP), for Cancer Care Group, P.C. (CCG), a...more

Morgan Lewis

Proactive Approach To Cybersecurity: Recent SEC guidance and enforcement actions suggest that reactive firms may be in the SEC’s...

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In an environment where even the largest and most powerful corporations have fallen victim to data breaches, it can be challenging to fathom how to protect against the sophisticated and ever-evolving threat of cyber attacks....more

King & Spalding

Investment Adviser Settles SEC Cybersecurity Enforcement Action; SEC Issues Investor Alert

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On September 22, the U.S. Securities and Exchange Commission (“SEC”) and R.T. Jones Capital Equities Management, Inc. (“R.T. Jones”), a St. Louis-based investment adviser, settled charges that R.T. Jones failed to adopt...more

Foley & Lardner LLP

SEC Brings First Cybersecurity Enforcement Proceeding in Wake of Risk Alert

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Highlights Areas of High Risk and Examination Priorities for Financial Industry Firms - On September 15, the U.S. Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections and Examinations (OCIE),...more

Manatt, Phelps & Phillips, LLP

SEC Ramps up Cybersecurity Scrutiny With Examination Priorities and an Enforcement Action

Why it matters - Signaling that it will continue to increase its scrutiny of firms' cybersecurity readiness, the Office of Compliance, Inspections and Examinations of the Securities and Exchange Commission (SEC) issued a...more

Foley Hoag LLP - Security, Privacy and the...

The SEC Charges Investment Adviser with Violating Regulation S-P by Failing to Adopt Cybersecurity Policies and Procedures

In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to...more

Proskauer on Privacy

SEC Announces Cybersecurity Enforcement Action

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On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation...more

McDermott Will & Emery

OCR Enforcement Trends

On April 27, 2015, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced a resolution agreement with Cornell Prescription Pharmacy (CPP) pursuant to which CPP paid a $125,000...more

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