Information Sharing

News & Analysis as of

U.S. Attorney General Discusses DOJ’s Global Cybercrime Initiatives at Europol

On September 16, U.S. Attorney General Loretta Lynch addressed the European Cybercrime Center at Europol, where she highlighted recent and planned DOJ initiatives related to global cybercrime and cyber threat efforts and...more

Treasury Deputy Secretary Raskin Delivers Remarks On Cybersecurity and Insurance

On September 10, Deputy Secretary of the Treasury Sarah Bloom Raskin delivered remarks at the Center for Strategic and International Studies Strategic Technologies Program in Washington, D.C. After summarizing threats posed...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Draft Law Transposing the European Directive on the Automatic Exchange of Information submitted to Parliament - The draft Luxembourg law to transpose Council Directive 2014/107/EU (of 9 December 2014, which amends...more

Financial Services Report, Fall 2015

BELTWAY - Straight Out of the Seventh Circuit The Seventh Circuit recently affirmed a lower court’s ruling that the SEC cannot be sued in district court to stop it from bringing an administrative action. Bebo v. SEC, No....more

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

California’s Governor Strengthens Cybersecurity Preparedness With Executive Order

On August 31, 2015, California Governor Edmund G. Brown Jr. signed Executive Order B-34-15. The Order directs the Governor’s Office of Emergency Services to establish the California Cybersecurity Integration Center...more

California Governor Signs Executive Order Aimed At Strengthening Cybersecurity Strategy

On August 31, California Governor Edmund G. Brown signed Executive Order B-34-15. A response to recent cyber-attacks, this order is intended to bolster the state’s preparedness, to improve inter-agency, cross-sector...more

"IRS Implements Final Changes to Advance Pricing Agreement Process"

On August 12, 2015, the IRS issued Rev. Proc. 2015-41, which sets out the procedures for pursuing advance pricing agreements (APAs). The new revenue procedure replaces Rev. Proc. 2006-9 and finalizes revenue procedures...more

FinCEN Proposes New Anti-Money Laundering Rule For Investment Advisers

On August 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM), which would impose anti-money laundering (AML), suspicious activity reporting,...more

FinCEN Proposes New Rule Requiring Anti-Money Laundering Programs for Registered Investment Advisers

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would define investment advisers registered (or required to be registered) with the Securities and...more

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to...more

FinCEN Proposes AML Program Rule for Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

Update: Department of Defense Privacy and Information Handling/Department of Defense Proposed Rule

There is a lot going on with the government right now regarding information and privacy. As the saying goes, it is not a matter of if the system is hacked or taken advantage of but when. This update will quickly cover two...more

5 Ways Employers Can Spend A Lot Less Time In Court

“An apple a day keeps the doctor lawyer away.” Here are five easy and inexpensive things that employers can do to minimize their risk of being sued and maximize their chances of victory if they do get sued. None of these...more

We’re All About Sharing Cyber Information: The National Cybersecurity and Communications Integration Center

Amidst the maelstrom of unceasing cyber attacks and intrusions, the National Cybersecurity and Communications Integration Center (NCCIC or Center) assumes a front-and-center role as the government command and communication...more

Senate Could Take Up Cybersecurity Bill Before August Recess

While the U.S. House of Representatives has already adjourned for the month-long August recess, the U.S. Senate remains in session and could take up a measure to address cybersecurity information-sharing as one of its last...more

Cloud Sharing Apps Scrutinized for ePHI

In a relatively short time period, the direct costs of document storage have dropped precipitously, and cloud-based document storage has become ubiquitous. Clearly, this is a wave of the future. But a recent settlement...more

Internet-Based Document Sharing Applications Scrutinized

On July 8, 2015, the U.S. Department of Health and Human Services, Office for Civil Rights (OCR) and St. Elizabeth’s Medical Center (SEMC) located in Boston, Massachusetts entered into an agreement following an investigation...more

Auto manufacturers’ alliance create information sharing and analysis center for cyber-threats

Twelve automakers that make up the Alliance of Automobile Manufacturers (AAM) have agreed to form an information sharing and analysis center (Auto ISAC) that will facilitate the sharing of cyber security data to stay abreast...more

Hospital’s Cloud-Based Document-Sharing Practices Lead to $218,400 HIPAA Settlement

On July 10, 2015, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) announced a substantial settlement with St. Elizabeth’s Medical Center (SEMC). Under the terms of the settlement, the hospital...more

FTC Releases Data Security Guide for Businesses

The Federal Trade Commission (FTC) has released a guide for businesses with practical tips and advice to help organizations better secure their data. The guide, Start With Security, draws on more than 50 data security...more

2015 Data Breach Legislation Six Month Review: Many Proposals, Few Changes

The heat of summer may be upon us, but in Congress and in many state legislatures the attitude toward passing major data breach legislation has considerably cooled. We predicted some months ago that 2015 might be the...more

Two House Bills seek to address sharing of mental health information under HIPAA

The Health Subcommittee of the U.S. House Energy and Commerce Committee held a hearing last week to consider two bills addressing current limits on the sharing of mental health information under HIPAA. The first bill, the...more

PIPEDA Amendments In-Force

Amendments to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) are frequently proposed but just as frequently die on the order paper. Bill S-4, which proposed the most significant amendments to...more

Industry Weighs In on Data Security, Cybersecurity Legislation

Industry Weighs In on Data Security, Cybersecurity Legislation: Why it matters - Members of the financial industry were able to share their positions and voice concerns at a recent hearing held by the House...more

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