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Managing these risks at a single company should be straightforward. Executives and CISOs may be personally held accountable for cyber failings, negligence, breaches, and inadequate disclosure around cyber vulnerabilities and...more
At this point, it is self-evident that companies are grappling with an ever-evolving (think: tougher) cyber risk terrain. However, two recent cases against companies and their Chief Information Security Officers (CISOs),...more
On October 30, 2023, the Securities and Exchange Commission (SEC) announced a civil suit against SolarWinds and their chief information security officer (CISO) for fraudulent cybersecurity information. The SEC claims that...more
The Biden Administration Issues Executive Order on Artificial Intelligence - On October 30, 2023, President Biden signed an Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence (the “Order”)...more
Any time a regulation is put forth, there is always a level of uncertainty, especially regarding understanding the roles and responsibilities of key business leaders. The SEC’s new cybersecurity final rule means heightened...more
The Federal Trade Commission updated its “Standards for Safeguarding Customer Information” (“Safeguards Rule”) and extended the compliance deadline to June 9, 2023. Some entities still may be wondering – “Do these regulations...more
On April 4, 2023, the office of Illinois Attorney General Kwame Raoul was joined by leaders in technology and law enforcement for a full-day symposium designed to inform CISOs, CTOs and CIOs on how best to protect their...more
On October 5, 2022, after a monthlong jury trial, former Uber Chief Information Security Officer Joseph Sullivan was found guilty of obstructing proceedings of the Federal Trade Commission (FTC) and misprision of a felony...more
On October 27, 2021 the FTC issued a final rule (the “Final Rule”) amending 16 CFR Part 134, Standards for Safeguarding Customer Information (“Safeguards Rule”), after a period of notice and comment. While the existing...more
Following a 3-2 vote, the Federal Trade Commission (FTC) recently announced amendments to the Safeguards Rule under the Gramm-Leach-Bliley Act. The Safeguards Rule was first promulgated in 2002. The revisions are meant to...more
The Federal Trade Commission held a virtual workshop on July 13, 2020, to examine its proposed amendments to the Safeguards Rule. The Safeguards Rule, promulgated under the Gramm-Leach-Bliley Act, requires financial...more
The FTC recently summarized three major changes it made to its orders in data security cases. In a blog signaling these changes, the FTC Indicated that some of the things it has been requiring of companies in 2019 are here to...more
The Federal Trade Commission (“FTC”) issued notices on March 5 seeking public comment on proposed amendments to the regulations implementing the Gramm-Leach-Bliley Act (“GLBA”), commonly known as the Safeguards Rule and...more
As we’ve been predicting, the Cybersecurity Regulation adopted by the NY DFS for insurance, banking and other financial services continues to drive the conversation in the U.S. The latest manifestation is the FTC proposal,...more
The Federal Trade Commission (FTC) announced this week that it is seeking comments on proposed amendments to the Privacy Rule and Safeguards Rule under the Gramm-Leach-Bliley Act (GLBA)....more
Since President Trump’s inauguration, cybersecurity has been in the news almost daily – often on the front page. The U.S. Government is facing a wide array of challenges in cybersecurity, impacting both domestic and foreign...more
In Case You Missed It: The Federal Trade Commission has opened a public comment period to evaluate its Safeguards Rule (16. C.F.R. § 314.3). Under the Gramm-Leach-Bililey Act (GLBA), which regulates financial institutions,...more
Before committing resources to a potential investment, private equity firms should aggressively evaluate a target company’s cyber risks and cyber preparedness. Some target companies are naturally more exposed to cyber risk...more