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Final DoD Cybersecurity Maturity Model Certification Rule Will Bring Compliance Challenges, Increased False Claims Act Risk

On October 11, 2024, the U.S. Department of Defense (DoD) at long last published a final rule establishing the Cybersecurity Maturity Model Certification (CMMC) Program (the Final Rule)...more

It’s December 18, 2023: Do You Know Where Your Cybersecurity Disclosure Controls and Procedures Are

The requirement to disclose material cybersecurity events under new Item 1.05 of Form 8-K takes effect today (other than for smaller reporting companies, for which the new requirement will take effect on June 15, 2024)....more

White House Orders New Rules on U.S. Outbound Investment

The Biden Administration has issued its long-awaited Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern (“EO”), which will create a new...more

Executive Order Raises Regulatory Risks for Foreign Investment Across U.S. Economy

On September 15, 2022, President Biden signed an Executive Order (EO) identifying economic sectors that merit special attention for review by the Committee on Foreign Investment in the United States (CFIUS or the Committee)....more

SEC Proposes New Public Company Cybersecurity Disclosure Rules

On March 9, 2022, the SEC proposed rules, by a 3-1 vote, that are intended to enhance disclosures about cybersecurity risk management, strategy, governance, and incident reporting by public companies. The proposed rules are...more

FTC Finalizes Financial Institution Safeguards Rule

On October 27, 2021, the Federal Trade Commission (FTC) announced a newly updated rule under the Gramm-Leach-Bliley Act (GLBA) intended to require financial institutions to strengthen their data security safeguards to protect...more

DOJ Launches “Civil Cyber Fraud Initiative” to Use the False Claims Act to Address Cybersecurity-Related Conduct

The US Department of Justice (DOJ) recently announced plans to use the False Claims Act (FCA) to pursue cybersecurity-related fraud by government contractors, subcontractors and grant recipients, including for providing...more

President Biden Signs Executive Order Designed To Improve Federal Government Cybersecurity

On Wednesday, May 12, 2021, President Biden issued an ambitious and sweeping Executive Order focused on combating digital threats to US networks and infrastructure. The Executive Order on Improving the Nation’s Cybersecurity...more

Compliance Deadline Reached for DoD Contractor Security Controls Requirements

Under the Department of Defense (DoD) final Defense Federal Acquisition Regulation Supplement (DFARS) rule on Network Penetration Reporting and Contracting for Cloud Services, DoD contractors maintaining, processing, or...more

Energy Sector Alert Series: Cybersecurity Developments in the Energy Sector

In this eight-week alert series, we are providing a broad look at current and emerging issues facing the energy sector. Lawyers from across the firm are discussing issues ranging from cybersecurity, antitrust and intellectual...more

Department of Defense Issues Final Version of Key Cybersecurity Rule

On October 21, 2016, the Department of Defense (DoD) issued its final rule on Network Penetration Reporting and Contracting for Cloud Services, amending an interim version issued on August 26, 2015, and revised on December...more

A Closer Look at Cybersecurity Legislation and Regulations in the US and Abroad - Global Overview

With interconnectivity and use of digital storage expanding, cyberthreats posed by nation states, commercial competitors, company insiders, transnational organised crime and ‘hacktivists’ are growing on a global basis. Recent...more

Department of Defense Revises Landmark Cybersecurity Rule, Extends Deadline for Some Compliance Requirements

On December 30, 2015, the Department of Defense (DoD) issued a second interim rule on Network Penetration Reporting and Contracting for Cloud Services, amending an earlier version issued on August 26, 2015. The new, amended...more

Congress Enacts Major Cybersecurity Legislation

On December 18, 2015, Congress passed, and the President signed, the Cybersecurity Act of 2015, which provides authorization and liability protection for cybersecurity monitoring and information-sharing and authorization for...more

Department of Justice Issues Best Practices Guidance on Cyber Incidents

On Wednesday, April 29, the US Department of Justice released guidance titled “Best Practices for Victim Response and Reporting of Cyber Incidents.” The guidance outlines steps companies should take before, during, and after...more

Report Highlights Bank Vendor Cybersecurity Vulnerabilities

On April 9, the New York State Department of Financial Services (NYDFS) released a report on bank vendor cybersecurity that highlights the risk that hackers will use third-party service providers to gain access to bank data....more

Executive Order Creates Cybersecurity Sanctions Framework

On April 1, 2015, President Obama issued an Executive Order authorizing the imposition of sanctions against designated individuals or entities found to be engaged in malicious cyber activity, including various forms of...more

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