Ransomware attacks are hitting record highs in 2024 and show no sign of slowing down as new criminal groups enter the scene and employ a variety of evolving tactics. This post identifies key highlights of ransomware activity...more
A recent joint advisory from the Cybersecurity and Infrastructure Security Agency (CISA), the Federal Bureau of Investigation (FBI) and the Department of Defense Cyber Crime Center (DC3) warns of increased collaboration...more
On June 24, 2024, the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued five new Compliance and Disclosure Interpretations (“C&DIs”) related to the disclosure of “material”...more
7/11/2024
/ Corporate Governance ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Disclosure Requirements ,
Form 8-K ,
Publicly-Traded Companies ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
Does the R.R. Donnelley settlement mean heightened Securities and Exchange Commission (SEC) involvement in regulating public companies’ cybersecurity policies and practices? Our Securities Litigation, Privacy, Cyber & Data...more
7/2/2024
/ Cease and Desist Orders ,
Cybersecurity ,
Data Security ,
Disclosure ,
Enforcement Actions ,
Ransomware ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Regulation ,
Sensitive Personal Information ,
Settlement
On May 7, 2024, the United States unsealed an indictment against Dmitry Yuryevich Khoroshev, one of the leaders of the Russian-based ransomware group LockBit, for his alleged involvement in developing and distributing the...more
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)
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 December 19, 2023, the Justice Department (“DOJ”) announced a disruption campaign against the Blackcat ransomware group. In the same press release, they also stated that the Federal Bureau of Investigation (“FBI”) had...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
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
On June 7, 2023, the Federal Bureau of Investigation (FBI) and the Cybersecurity and Infrastructure Security Agency (CISA) released a Joint Cybersecurity Advisory in connection with a recent zero-day (or previously...more
Our Privacy, Cyber & Data Strategy and White Collar, Government & Internal Investigations teams offer key takeaways that companies should consider in the wake of the Justice Department’s first prosecution of a corporate...more
Selected Developments in U.S. Law - U.S. Department of Commerce Announces the Establishment of a Global CBPR Forum On April 21, 2022, Canada, Japan, South Korea, the Philippines, Singapore, Taiwan, and the United States...more
5/11/2022
/ California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Cyber Attacks ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Digital Assets ,
Fraud ,
Personal Information ,
Popular ,
Privacy Laws ,
Ransomware
On March 1, the Senate unanimously passed the Strengthening American Cybersecurity Act of 2022, which will require critical infrastructure companies to report significant cyber-incidents and all ransom payments to the...more
3/18/2022
/ Biden Administration ,
Covered Entities ,
Critical Infrastructure Sectors ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
New Legislation ,
Notice and Comment ,
Proposed Rules ,
Ransomware
On February 9, 2022 the United States, United Kingdom, and Australia issued a joint Cybersecurity Advisory on the “Increased Globalized Threat of Ransomware” against critical infrastructure sectors (“Advisory”). The Advisory...more
Selected Developments in U.S. Law - SEC Proposed Rule Will Require Private Funds to Report Certain Cyber Events On January 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules to enhance hedge fund...more
2/9/2022
/ China ,
Cyber Incident Reporting ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Breach ,
Data Privacy ,
Data Security ,
Data Subject Access Requests ,
Federal Trade Commission (FTC) ,
General Data Protection Regulation (GDPR) ,
International Data Transfers ,
Malware ,
Multi-Factor Authentication ,
NYDFS ,
Personal Data ,
Popular ,
Ransomware ,
Reporting Requirements ,
Russia ,
Ukraine
Russia’s Federal Security Service (“FSB”) issued a press release on January 14, 2022 claiming that it dismantled the REvil ransomware gang by arresting 14 suspected members and seizing computer equipment, luxury vehicles,...more
On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” While this advisory...more
Selected Developments in U.S. Law - Colorado Privacy Act Becomes Third Comprehensive State Privacy Act in the United States - Our Privacy, Cyber & Data Strategy Team highlights some of the similarities and differences between...more
Ransom demands from cyber-attacks show no signs of slowing down, and the costs—both from ransom payments and repairing the damage—are rising precipitously. Our Privacy, Cyber & Data Strategy Team outlines six ways companies...more
The New York Department of Financial Services (NYDFS) issued new guidance this week intended to assist organizations in thwarting ransomware attacks. The guidance clarifies the NYDFS’ expectation that NYDFS-regulated...more
Companies face increasingly tough decision points in preparing for and responding to the proliferation of ransomware attacks. Our Privacy, Cyber & Data Strategy Group outlines seven issues for general counsel to consider as...more
Selected Developments in U.S. Law - NYDFS Issues Report on the SolarWinds Attack and Covered Entities’ Responses Following the SolarWinds cyber espionage attack and the resulting focus on supply chain risk, the New York...more
5/14/2021
/ Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Breach ,
Data Security ,
FBI ,
NYDFS ,
Phishing Scams ,
Popular ,
Ransomware ,
Safe Harbors ,
Settlement ,
SolarWinds ,
Supply Chain
Selected Developments in U.S. Law - Fifth Circuit Decision Raises Cyber Enforcement Complications for the U.S. Department of Health and Human Services As the Biden Administration begins detailing its regulatory and...more
2/18/2021
/ Attorney-Client Privilege ,
Biden Administration ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Security ,
Department of Health and Human Services (HHS) ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
State Privacy Laws ,
Work-Product Doctrine