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Can Cyber Threat Intelligence Sharing Continue After CISA 2015’s Lapse?

The expiration of the Cybersecurity Information Sharing Act of 2015 (CISA 2015 or the Act) on September 30, 2025 has quietly reshaped how organizations should approach cyber threat intelligence sharing. For the past decade,...more

NIH Follows in FDA’s Footsteps and Adopts “Bulk Sensitive Data” Policy That Goes Beyond DOJ Rule Requirements

The National Institutes of Health (“NIH”) has become the latest federal agency to impose obligations that go beyond those required by the watershed U.S. Department of Justice (“DOJ”) data security program (“DSP”) with its new...more

[Webinar] North Korean IT Workers: Recent Developments, Risks & Best Practices - October 21st, 1:00 pm ET

Increasingly, the DPRK is disguising remote North Korean IT workers as U.S. based contractors—allowing them to evade U.S. sanctions, generate revenue for the regime, and potentially compromise networks. In this webinar, MoFo...more

Communicating with the SEC When Your Organization Suffers a Cybersecurity Incident

The Securities and Exchange Commission (SEC) has made clear—through its rulemaking, enforcement actions, public statements, and formidable “Crypto Assets and Cyber Unit” within the Division of Enforcement—that public...more

[Webinar] The Lawyer’s Field Guide to Cybersecurity Incidents - October 7th, 1:00 pm ET

When a cyber incident strikes, time is short and the stakes are high. Lawyers are often called upon to coordinate response efforts, ensure regulatory and contractual obligations are met, direct third party experts — all while...more

SEC Caps 2024 with Another Cyber Enforcement Action

The SEC continues to leave its mark as a federal cybersecurity enforcer and closed out the year by charging another company with making misleading statements about a cybersecurity attack and failing to maintain cyber-related...more

A New Frontier for SEC Cybersecurity Enforcement? The SEC Charges SolarWinds and its CISO with Securities Fraud

Earlier this week, the SEC accused SolarWinds Corporation (“SolarWinds” or the “Company”) and its Chief Information Security Officer (“CISO”) of committing scienter-based securities fraud, among other violations, for...more

SEC Delays Finalized Cyber Rules Until October 2023

Based on updates to its rulemaking agenda that were released last week, the U.S. Securities and Exchange Commission (SEC) has delayed approval of two cybersecurity rules until at least October 2023. Both proposed rules were...more

OFAC Issues New Ransomware Guidance And First Sanctions Designation Against Virtual Currency Exchange

In the Biden Administration’s latest effort to respond to the growing threat of ransomware attacks, on September 21, 2021, the U.S. Department of the Treasury (“Treasury”) announced new sanctions and ransomware guidance in an...more

Pay At Your Own Risk: OFAC Issues Advisory On Potential Sanctions Risks Stemming From Ransomware Payments

On Thursday, October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an advisory highlighting potential sanctions risks associated with ransomware payments related to malicious...more

Should Employers Require Employees To Wear Facemasks?

As employers begin considering return to work strategies, many are wondering whether they should permit or require individuals to wear facemasks at work. It may be surprising to many companies, but the Occupational Safety and...more

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Financial Services Report – Summer 2018

BELTWAY - The Wayback Machine - Congress passed, and on May 24, 2018, the president signed into law, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155). The law makes significant changes to...more

Preparing for a Data Security Breach: Ten Important Steps to Take

Is your company prepared to respond to a data security breach? For many companies, even reading this question causes some anxiety. However, being prepared for what seems like the inevitable—a security breach—can be the...more

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

Financial Services Report, Spring 2016

Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more

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