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EU and Germany Lay Groundwork for the Use of Medical Data for Research and AI Training

Both the EU and Germany are taking significant steps to accelerate digitalization in the health sector and facilitate the exchange and use of health data for research and innovation purposes. They aim to improve...more

EU Adopts First of a Series of Voluntary Cybersecurity Certification Schemes

On January 31, 2024, the European Commission (EC) adopted the first of a series of initiatives to harmonize cybersecurity certification across the EU: the European Cybersecurity Scheme on Common Criteria (EUCC). While EUCC...more

FCC Approves Voluntary Internet-of-Things Cybersecurity Labeling Program

The Federal Communications Commission (FCC) recently approved a voluntary Internet of Things (IoT) Labeling Program, which allows manufacturers of IoT products to earn the FCC’s approval to display a “U.S. Cyber Trust Mark”...more

A Fracturing Data Environment: Executive Order Portends Major Changes to US Data Management

On February 28, 2024, President Biden issued Executive Order 14117 (the EO) on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” that would...more

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

Know Your Cloud Customer: Commerce Department Proposes To Regulate Foreign Access to US IaaS Products

On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more

Emerging Expectations: The Board’s Role in Oversight of Cybersecurity Risks

Key Points - - New SEC rules from 2023 require public companies to report material cybersecurity incidents promptly and detail their cybersecurity risk management strategies in annual reports — requirements that increase...more

Latest Text of EU AI Act Proposes Expanding Obligations for High-Risk and General AI Systems and Banning a Third Category

On 21 January 2024, a near complete draft version of the proposed text for the EU AI Act was unofficially shared with the public by a European media publication, after which a senior advisor in the European Parliament shared...more

2024 Insights: Other Regulatory Developments

AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more

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

Latest Draft of the European Cybersecurity Certification Scheme for Cloud Services – Updates for Non-EU Cloud Service Providers

A recent draft of the EU Agency for Cybersecurity’s (ENISA’s) European Union Cybersecurity Certification Scheme on Cloud Services (EUCS) reveals what requirements are currently being considered (and what requirements have...more

China Intends To Ease Controls Over Cross-Border Data Transfers

On September 28, 2023, the Cyberspace Administration of China (CAC) published the draft Provisions on Regulating and Promoting Cross-Border Data Transfers (Draft Provisions). If adopted into law in their current form, the...more

What Does the SEC’s Complaint Against SolarWinds Mean for CISOs and Boards?

On October 30, 2023, the SEC filed a litigated complaint against SolarWinds, a software development company, and Timothy Brown, its chief information security officer (CISO). The SEC alleges that from October 2018, when...more

AI Insights: Biden Administration Passes Sweeping Executive Order on Artificial Intelligence

On October 30, the U.S. government released its long-awaited, sweeping executive order (the AI EO or Order) on artificial intelligence (AI). The Order directs various U.S. government departments and agencies to evaluate AI...more

Private Equity CISO Fireside Chat – Cybersecurity Leadership in the Age of Generative AI

Partner and co-head of Skadden’s Cybersecurity and Data Privacy practice David Simon recently sat down with two chief information security officers (CISOs) from the private equity sector as part of the firm’s National Cyber...more

DORA – Key Considerations for Alternative Investment Funds

The EU Digital Operational Resilience Act (Regulation (EU) 2022/2554) (DORA) creates a regulatory framework intended to enhance the operational resilience of the financial sector by establishing uniform requirements for the...more

Cyber Fraud Alleged by Former CIO for Purported Noncompliance With DoD Cyber Requirements

A recently unsealed case against Pennsylvania State University: - Serves as yet another example of the increased use of the False Claims Act (FCA) in cybersecurity enforcement. - Underscores the need for companies...more

Federal Report Proposes Harmonization of Divergent Cyber Incident Reporting Regimes

On September 20, 2023, the U.S. Department of Homeland Security released a report outlining the varied and sometimes conflicting reporting requirements that private entities face when they are victims of a cyber incident. The...more

Privacy & Cybersecurity Update - September 2023

In this month’s Privacy & Cybersecurity Update, we examine Delaware’s new comprehensive data privacy law, a joint statement by 12 data protection authorities on data scraping and data protection, a district court ruling on a...more

Privacy & Cybersecurity Update - August 2023

In this month’s Privacy & Cybersecurity Update, we analyze the Biden administration’s proposed cybersecurity labeling program for smart devices, NIST’s extensive overhaul of its cybersecurity framework, and data privacy law...more

Privacy & Cybersecurity Update - July 2023

In this month’s Privacy & Cybersecurity Update, we examine the newly established data privacy framework between the EU and U.S. and new consumer privacy laws in Oregon and Texas. We also review a court ruling that delayed...more

SEC Adopts Rules for Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) voted 3-2 to adopt final rules that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and...more

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