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Deadline Ahead: NYDFS Compliance Notifications are due by April 15

Businesses that are subject to the NYDFS Cybersecurity Regulations have four weeks left to submit their annual notices of compliance or acknowledge their noncompliance. When the regulations were amended in 2023, several of...more

New York Amends its Data Breach Notification Law

Keypoint: New York has amended its data breach notification law twice in the last 60 days to (1) add a 30-day deadline for notifying affected residents, (2) clarify that covered financial entities must still notify the New...more

The Proposed Rule to Amend FAR Guidance on Safeguarding CUI – Care to Comment?

The FAR Council issued a proposed rule that would amend the several FAR provisions and add new clauses to provide guidance on the safe handling of CUI. Public comments on the proposed rule are being accepted until March 17,...more

Cybersecurity and Solar Power Vulnerability

As noted , the renewable energy sector faces growing concerns over its vulnerability to cyberattacks. Since then, the situation has not improved; the U.S. electrical grid has grown more vulnerable to cyberattacks, with...more

New York State Department of Health Adopts Hospital Cybersecurity Regulations

In November 2023, New York Governor Kathy Hochul announced proposed regulations that would be the first state regulations for hospitals in New York. The governor described the proposed regulation as a “nation-leading...more

NYDFS Warns Against the Threat of Accidentally Hiring North Korean Remote IT Workers

Keypoint: The New York State Department of Financial Services (NYDFS) issued an industry letter outlining the threats posed to U.S. companies who hire remote technology workers linked to North Korea and may embezzle funds...more

NYDFS Issues Guidance to Mitigate AI Cybersecurity Risks

Keypoint: The New York Department of Financial Services (NYDFS) circulated an industry letter offering guidance to NYDFS “Covered Entities” for assessing and managing AI-related cybersecurity risks, including threats...more

Texas Attorney General Reaches Generative AI Settlement

Keypoint: The Texas Attorney General reaches a first-of-its-kind settlement with a healthcare company that provides generative AI products. On September 18, 2024, the Texas Attorney General announced that it had reached a...more

Key Considerations in AI-Related Contracts

Keypoint: Companies onboarding AI products and services need to understand the potential risks associated with these products and implement contractual provisions to manage them. With the rapid emergence of artificial...more

White House Issues AI Policies Intended to Safeguard American Interests

The White House has announced a set of binding Artificial Intelligence (AI) policies for federal agencies, which are intended to protect the privacy, rights, and safety of the American people. Other than federal contractors...more

The Justice Insiders Podcast - Human Beings: Cybersecurity's Most Fragile Attack Surface [Audio]

Host Gregg N. Sofer welcomes Husch Blackwell’s Erik Dullea to the podcast to explore how human error factors into cybersecurity efforts. Most data breaches trace back to some form of human error, and an approach to...more

The Federal Communications Commission Updates its 2007 Breach Disclosure Regulations

Key Point: The FCC revised its breach notification rules for telecommunication providers to broaden the instances when notifications are required, but even with limited exceptions to the new requirements, the final rule...more

Federal Trade Commission Amends GLBA’s Safeguards Rule

Key Point: The Federal Trade Commission (FTC) has amended the Safeguards Rule to require non-banking financial institutions to inform the FTC within 30 days of discovering any unauthorized acquisition of unencrypted customer...more

The Invitation to Streamline Cybersecurity Regulations

Keypoint: To advance the National Cybersecurity Strategy, the Office of the National Cyber Director is soliciting public comments to harmonize cybersecurity regulations, with comments due by October 31, 2023. In March 2023,...more

The Justice Insiders Podcast: Incidents in the Material World: SEC Adopts New Cybersecurity Rules [Audio]

Host Gregg N. Sofer welcomes Husch Blackwell partner Erik Dullea to the podcast where we discuss risk management, strategy, governance, and incident disclosure in the context of the Security and Exchange Commission’s recently...more

Twelve Planning Tips to Avoid Complications with the SEC’s Cybersecurity Disclosure Rules: Part III

Key Point: The decision making processes to determine whether a cybersecurity incident is material or not, should include documenting the factors behind each determination and should be practiced before an incident...more

Twelve Planning Tips to Avoid Complications with the SEC’s Cybersecurity Disclosure Rules: Part II

Part I of this blog series discussed the compliance dates and the new definitions in the U.S. Securities Exchange Commission’s (the “SEC”) final rules (the “adopting release”) for cybersecurity disclosures. In Part II, we...more

Twelve Planning Tips to Avoid Complications with the SEC’s Cybersecurity Disclosure Rules: Part I

Key Point: To avoid inadvertently increasing enforcement and litigation risks, companies should consider these suggestions to minimize headaches with the SEC’s final rules that mandate (a) disclosures in annual report of...more

OSHA issues ANPRM on Heat Injury and Illness Prevention

On October 27, 2021, OSHA issued an Advance Notice of Proposed Rulemaking (ANPRM) on Heat Injury & Illness Prevention in Outdoor and Indoor Work Settings. 86 Fed. Reg. 59309 (Oct. 27, 2021). As announced in the ANPRM, OSHA is...more

Doug Parker Receives Senate Confirmation as the New Head of OSHA

On October 25, 2021 the US Senate confirmed President Biden’s nominee Doug Parker to be the next Assistant Secretary of Labor and leader of the Occupational Safety and Health Administration (OSHA). Mr. Parker will be the...more

OSHA Seeks Public Feedback On The Whistleblower Protection Program

On October 13, 2021, from 2:00 – 5:00 p.m. Eastern Time, the Occupational Safety and Health Administration (OSHA) will hold a virtual meeting (via telephone and Microsoft Teams) to receive public comments and suggestions...more

MSHA Proposes A Requirement For Written Safety Programs For Surface Mobile Equipment

On September 9, 2021, MSHA expects to publish a Proposed Rule requiring mine operators to develop and implement written safety programs for their powered haulage equipment used at surface mines and surface areas of...more

The Private Sector Should Heed White House Warning On Cyber Resilience Because Compliance Is Coming

The increased concern about ransomware incidents from both quantitative and severity standpoints, spurred the White House to urge corporate business leaders to improve their defenses and resilience posture against ransomware...more

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