Threat actors are evolving. Our Privacy, Cyber & Data Strategy Team explains how ransomware gangs have changed their tactics and how companies can respond to the threat while navigating new scrutiny from investors and...more
2/26/2024
/ Corporate Counsel ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Data Security ,
Data Theft ,
NYDFS ,
Popular ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC)
Recently, there has been a surge in alerts and warnings concerning cyberattacks by People’s Republic of China (PRC) state-sponsored threat actors on U.S. critical infrastructure. On February 7, 2024, the Federal Bureau of...more
On January 24, 2024, the U.K.’s National Cyber Security Centre (NCSC) released a new report, The near-term impact of AI on the cyber threat, detailing how Artificial Intelligence (AI) will impact the effectiveness of cyber...more
On January 5, 2024, the New York Attorney General’s Office (“NY AG”) announced a settlement with Refuah Health Center, Inc. (“Refuah”) based on the company’s alleged failures to appropriately safeguard its patients’...more
Our Securities and Privacy, Cyber & Data Strategy teams unpack the Department of Justice’s (DOJ) process for companies seeking to delay Form 8-K disclosures under the Securities and Exchange Commission’s (SEC) cybersecurity...more
Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more
11/13/2023
/ Chief Information Security Officer (CISO) ,
Corporate Liability ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
The Federal Bureau of Investigation (FBI) issued a Private Industry Notification on September 27, 2023, highlighting two concerning ransomware trends and providing companies with guidance on mitigating potential threat actor...more
On September 27, 2023, The U.S. National Security Agency (NSA), the U.S. Federal Bureau of Investigation (FBI), the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the Japanese National Police Agency (NPA), and...more
Publications and Advisories - July 31, 2023 – Dave Brown, Kate Hanniford, Kim Peretti, Julia Mediamolle, Cara Peterman, Sierra Shear, Kristen Bartolotta, and Kezia Osunsade published “Securities Law, Securities Litigation,...more
8/10/2023
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
Civil Investigation Demand ,
COPPA ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Hackers ,
International Data Transfers ,
Online Safety for Children ,
Popular ,
Ransomware ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Standard Contractual Clauses ,
Telehealth
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more
On June 13, 2023, the Securities and Exchange Commission (“SEC”) published its Spring 2023 rulemaking agenda that delayed finalizing the proposed Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure...more
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more
Publications and Advisories - April 5, 2023 – Kate Hanniford and Elinor Hiller published “Healthy Byte: White House and HHS Both Update Their Cybersecurity Guidance.”...more
Our Privacy, Cyber & Data Strategy Team breaks down how the two dozen strategic objectives in Biden’s National Cybersecurity Strategy will fundamentally shift how the United States allocates roles, responsibilities, and...more
Publications and Advisories - February 10, 2023 – Kathleen Benway, David Keating, and Sara Pullen Guercio published “Privacy, Cyber & Data Strategy / Consumer Protection/FTC Advisory: Limit Your Health Data Sharing and Call...more
2/15/2023
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
FCC ,
Federal Trade Commission (FTC) ,
Personal Information ,
Popular ,
State Privacy Laws
Artificial intelligence (AI) is expanding into more industries (often in surprising ways) and has inevitably caught the attention of federal and state regulators. Our Privacy, Cyber & Data Strategy Team summarizes the...more
12/12/2022
/ Algorithms ,
Artificial Intelligence ,
Corporate Counsel ,
Data Processors ,
Data Protection ,
Federal Trade Commission (FTC) ,
FinTech ,
Health Technology ,
Machine Learning ,
Medical Devices ,
NIST ,
Popular ,
Regulatory Oversight ,
Regulatory Standards ,
Risk Assessment ,
Technology Sector
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022....more
Selected U.S. Privacy and Cyber Updates - California Privacy Protection Agency Issues Notice of Modifications to Proposed CPRA Regulations - On November 3, 2022, the California Privacy Protection Agency (CPPA) issued a notice...more
The United Kingdom’s National Cyber Security Centre (NCSC) recently released its 2022 Annual Review, which reports on the state of cyber security threats in the country. As the UK’s technical authority for cyber security, the...more
On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic...more
On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help prepare for state cybersecurity exams and, ultimately, improve...more
Enhancing data security programs to protect personal information is a critical area companies cannot ignore. Our Privacy, Cyber & Data Strategy and Financial Services & Products groups unpack the latest moves by the Consumer...more