News & Analysis as of

Reporting Requirements Federal Bureau of Investigation

Health Care Compliance Association (HCCA)

Privacy Briefs: September 202

The HHS Centers for Medicare & Medicaid Services (CMS) and Wisconsin Physicians Service Insurance Corporation (WPS) are notifying 946,801 people whose protected health information or other personally identifiable information...more

Epiq

Federal Contractors Face Stricter Regulation Over Cyber Incident Response Reporting

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Last October, the Federal Acquisition Regulation (FAR) Council proposed two new rules, one of which that will influence cyber incident response practices. The scope is limited as it only applies to federal government...more

Mandelbaum Barrett PC

Navigating the New Cybersecurity Terrain: Implications of the FCC’s Latest Rule on Security Breach Notifications

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Introduction: On February 12, 2024, the Federal Communications Commission (FCC) finalized a critical cybersecurity rule, Sec. 64.2011, mandating telecommunications carriers and TRS (Telecommunications Relay Services)...more

Hahn Loeser & Parks LLP

Beware! Corporate Transparency Act Scams Target Business Owners

The Corporate Transparency Act (“CTA”) took effect on January 1, 2024, and with it comes new federal reporting requirements for many business owners across the United States. Unfortunately, the introduction of the CTA has...more

Paul Hastings LLP

FBI, DOJ, and SEC Publish Guidance on Requesting Delayed Reporting of Item 1.05, Material Cybersecurity Incidents, on Form 8-K

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On July 26 2023, the Securities and Exchange Commission (SEC) adopted final rules intended to enhance and standardize disclosures of cybersecurity risk management, strategy, governance, and incident reporting by public...more

Pillsbury Winthrop Shaw Pittman LLP

FCC Updates Data Breach Notification Rules

At its December meeting, the Federal Communications Commission approved a Report and Order modifying its data protection rules. The order expands the scope of protected data to include personally identifiable information....more

Faegre Drinker Biddle & Reath LLP

DOJ & FBI Issue New Guidelines for Delayed Reporting of Cyber Incidents to the SEC

Under the Securities and Exchange Commission’s (SEC) new Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule (cybersecurity rule), public companies subject to the cybersecurity rule must promptly...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

Wilson Sonsini Goodrich & Rosati

FBI, DOJ, and SEC Provide Guidance and Requirements for Requests to Delay Form 8-K Disclosures for Material Cybersecurity...

As discussed in a previous alert, on July 26, 2023, the U.S. Securities and Exchange Commission (SEC) approved final rules requiring that public companies report information regarding cybersecurity incidents within four...more

Mayer Brown

DOJ and FBI Announce Guidance on Seeking Delays in SEC 8-K Filings for Cyber Incidents

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On December 12, 2023, the Department of Justice (DOJ) issued guidelines for companies to follow in requesting that the Attorney General authorize delays of cyber incident disclosures required by the U.S. Securities and...more

Wiley Rein LLP

SEC Cyber Reporting Mandates: How to Request a National Security or Public Safety Delay

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On December 18, the Securities and Exchange Commission's (SEC) new disclosure requirements go into effect and will require public companies to publicly report material cybersecurity incidents within four days of making a...more

Balch & Bingham LLP

Joint Cybersecurity Advisory (“CSA”) Issued Regarding IRGC-Affiliated Cyber Threats to Multiple Sectors, including U.S. Water and...

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On December 1, 2023, the Federal Bureau of Investigation (“FBI”), Cybersecurity and Infrastructure Security Agency (“CISA”), National Security Agency (“NSA”), Environmental Protection Agency (“EPA”), and the Israel National...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

Foley Hoag LLP

FBI and CISA Issue Advisory on Scattered Spider Ransomware Attacks

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Large companies holding sensitive data – including financial services, telecommunications, business process outsourcing, hospitality, and cryptocurrency firms – as well as their IT helpdesks, are increasingly being targeted...more

McGlinchey Stafford

Vessel Owners: New Sexual Assault, Harassment Obligations under Defense Act Amendments

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Under 2023 amendments to the National Defense Authorization Act (NDAA), owners, masters, and managing operators of U.S. documented commercial vessels, are now required to immediately report incidents of harassment, sexual...more

BCLP

Ransomware - why paying up earns no credit with the UK's Data Protection Authority and others

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In a joint letter this summer, the UK’s data protection regulator (the ICO) and the UK’s National Cyber Security Centre (the NCSC) sought to convey some key messages to the legal profession relevant to advising clients...more

Pillsbury Winthrop Shaw Pittman LLP

Bipartisan Cyber Incident Reporting for Critical Infrastructure Act of 2022 Signed into Law

Under the new law, critical infrastructure owners and operators will be required to report significant cyber incidents to the Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA)...more

Alston & Bird

Executive Order Details Cybersecurity Changes For Public And Private Sector

Alston & Bird on

In a lengthy Executive Order issued on May 12, 2021 (the “Order”), the Biden Administration has taken steps “to make bold changes and significant investments” in both public and private sector cybersecurity “in order to...more

King & Spalding

Heightened Focus on Foreign Influence in Academia

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Department of Education Report Warns that Academic Institutions Are Failing to Meet Compliance Obligations in Fight Against Foreign Influence Last month the Department of Education (“DOE” or “Department”) released an...more

Sheppard Mullin Richter & Hampton LLP

The U.S. Government Investigates U.S. Universities Participating in the “Confucius Institutes” Program

In July, the U.S. Department of Education Notices of Investigation to four U.S. universities seeking information on the “Confucius Institutes” operating on their campuses. The investigations center on provisions of the Higher...more

Ballard Spahr LLP

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

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As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

Foodman CPAs & Advisors

FBI Is Focused On Professional Service Providers

James C. Barnacle, Chief of the Money Laundering Unit in the Financial Crimes Section, Criminal Investigation Division, of the FBI recently stated that there is a RENEWED emphasis on investigations targeting “ money...more

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