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California Delete Act Enforcement Sweep

Businesses that sell data regarding California residents have been put on notice by the California Privacy Protection Agency’s (the CPPA’s) recent aggressive enforcement of the California Delete Act. On October 30, 2024, the...more

California Passes Flurry of Year-End AI Legislation

In 2024, the California legislature passed 17 laws related to artificial intelligence (AI). These new laws cover various themes and industries, including but not limited to deepfakes, training data disclosures, health care,...more

NYDFS Issues Guidance on Cybersecurity Risks Arising from Artificial Intelligence

On October 16, 2024, the New York Department of Financial Services (NYDFS) issued an Industry Letter that discusses the cybersecurity risks associated with the use of artificial intelligence (AI) and outlines strategies to...more

U.S. Department of Commerce Proposes a New KYC Rule Applicable to U.S. IaaS Providers

On January 29, 2024, the U.S. Department of Commerce’s (Department) Bureau of Industry and Security issued a notice of proposed rulemaking (Proposed Rule) that proposes a new Customer Identification Program (CIP) and other...more

Final Interagency Guidance on Managing Risks Associated with Third-Party Relationships

On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more

Washington Passes the My Health My Data Act

On April 27, 2023, Washington’s Governor Inslee signed the My Health My Data Act (MHMDA) into law, adding a new wrinkle to the increasingly complex patchwork of state privacy laws. As opposed to the other recently enacted...more

The New Standard Contractual Clauses Deadline is Approaching

On June 4, 2021, the European Commission introduced the new set of Standard Contractual Clauses (“SCCs”), a primary mechanism for lawfully transferring personal data from Europe to the United States under the European Union’s...more

SEC Proposes New Cybersecurity Disclosure Rules for Public Companies

On March 9, 2022, the SEC proposed new rules (“Proposed Rules”) that would expand cybersecurity disclosures applicable to public companies subject to the reporting requirements of the Securities Exchange Act of 1934...more

Federal Agencies Announce a New 36-Hour Cybersecurity Incident Rule Reporting Requirement

On November 18, 2021, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the...more

FTC’s Amended Safeguards Rule Imposes Significant Requirements on Covered Entities

On October 27, 2021, the Federal Trade Commission (“FTC”) announced new updates to the Gramm-Leach-Bliley Act (“GLBA”) by amending the Standards for Safeguarding Customer Information, known as the “Safeguards Rule,” and...more

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