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DOJ’s Final Rule on Data Transfers: Impacts Across Industries

As of January 23, 2025, the regulation discussed below has not been withdrawn by the Trump administration and is not subject to automatic withdrawal under President Trump’s Executive Order freezing regulations. It currently...more

Proposed DOJ FARA Rules Would Increase Uncertainty for Global Companies Amid Heightened Enforcement

The U.S. Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) to update regulations under the Foreign Agents Registration Act of 1938 (FARA) on January 2, 2025. If adopted, DOJ’s proposed changes would...more

It’s Official: Cybersecurity Disclosure Is Coming This Year

The U.S. Securities and Exchange Commission (SEC) adopted final rules on July 26, 2023, requiring public companies to provide current disclosure, within what may be a short time window, about material cybersecurity incidents...more

Cybersecurity Implementation Plan Offers a Roadmap for Cyber Priorities

The Biden Administration recently reaffirmed its continued focus on cybersecurity by announcing an Implementation Plan for the National Cybersecurity Strategy (the Plan). The Plan provides a roadmap covering the policies and...more

CISA Seeks Input on New Cybersecurity Reporting Requirements

President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The background and contours of CIRCIA are discussed in a previous update. CIRCIA authorizes and...more

Forthcoming Disclosure and Security Requirements for Institutions Hosting Federally Funded Research

NSPM-33 National Security Presidential Memorandum-33 (NSPM-33) and implementation guidance from the National Science and Technology Council (NSTC) direct federal agencies to standardize and enhance disclosure and security...more

SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance

As cybersecurity threats to the private and public sectors increase, the government has continued its efforts to enhance cybersecurity outside of government-controlled systems. On March 9, 2022, the U.S. Securities and...more

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