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Takeaways From the Dismissal of SEC Claims Against SolarWinds and Its CISO

The U.S. District Court for the Southern District of New York has dismissed many of the Securities and Exchange Commission’s (SEC’s) claims against software development company SolarWinds and its chief information security...more

The EU’s Digital Operational Resilience Act (DORA) – 2024 Update

As implementation of the EU’s Digital Operational Resilience Act (DORA) approaches, financial market participants and their technology service providers (both in and out of Europe) face a critical compliance deadline. The new...more

ECB Mandates Board Expertise in Addressing ICT and Security Risks

Earlier this year, a dedicated policy prepared by the European Central Bank (ECB) came into effect requiring bank management bodies to broaden their collective understanding of and proficiency in identifying and dealing with...more

Contractors Settle Cyber Fraud Claims Alleging Ignored Security Measures

Two recent settlements under the False Claims Act (FCA): - Signal enhanced risk around cybersecurity for recipients of federal funds. - Underscore the need to assess compliance with cybersecurity requirements and...more

The London Space Law Symposium

On 9 May 2024, Skadden held the inaugural London Space Law Symposium, where six panels of Skadden representatives and industry experts discussed legal aspects of the new space economy. The event was held in the Naim Dangoor...more

Insights – June 2024

Explore the unique considerations for mergers and acquisitions in the AI sector, the return of IPOs, the implications of new Supreme Court decisions and other developments in this edition of Skadden’s quarterly Insights....more

The EU AI Act: What Businesses Need To Know

The newly approved Artificial Intelligence Act (AI Act or the Act) aims to create a secure and trustworthy environment for the development and use of AI in the European Union....more

SEC Amends Reg S-P To Strengthen Data Breach Response Requirements and Protect Investor Information

On May 16, 2024, the Securities and Exchange Commission (SEC) announced the adoption of amendments to Regulation S-P (Reg S-P), which broadly track the changes originally proposed in March 2023. The revised Reg S-P requires...more

The UK ICO Publishes Its Strategy on AI Governance

Rather than specifically regulating artificial intelligence (AI), the UK government has opted to rely on the existing web of laws and regulations applying to technology across a spectrum of sectors in its jurisdiction. But...more

Data Protection Rulings by European Regulators Offer Insights Into Their Security Expectations

Valuable insights into the measures European regulators expect businesses to take to protect data privacy can be found in a report from the European Data Protection Board (EDPB) summarizing decisions under the EU’s General...more

Utah Becomes First State To Enact AI-Centric Consumer Protection Law

On March 13, 2024, Utah enacted the Utah Artificial Intelligence Policy Act (UAIP), which imposes certain disclosure requirements on entities using generative AI tools with their customers, and limits an entity’s ability to...more

HHS Office for Civil Rights Reaches Second Health Care Ransomware Settlement

The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently announced its second settlement in four months growing out of a ransomware attack on a health care business. Maryland-based Green Ridge...more

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

Tennessee Law Addresses Proliferation of Deepfakes

Tennessee has enacted the Ensuring Likeness, Voice and Image Security (ELVIS) Act, which aims to protect individuals from the use of their persona in connection with “deepfakes” (i.e., fake content generated by artificial...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

AI Insights: Proposed FTC Order Suggests Blueprint for AI Adoption

A proposed settlement action filed on December 19, 2023, by the Federal Trade Commission (FTC) against Rite Aid Corp. highlights some of the key issues presented when companies use artificial intelligence (AI) for facial...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

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