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US Commerce Department Finalizes Rule on Connected Vehicles With Supply Chain Links to China and Russia

On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) addressing national security concerns regarding information and communications technology...more

President Biden Issues Executive Order on Strengthening and Promoting Innovation in the Nations Cybersecurity

INTRODUCTION... On January 16, 2025, President Biden issued an Executive Order (EO) on Strengthening and Promoting Innovation in the Nation’s Cybersecurity, to further address increasing threats from nation-state actors...more

US Department of the Treasury Issues Final Rule to Regulate Outbound Investments

On October 28, 2024, the US Department of the Treasury (“Treasury”) issued a Final Rule to require the notification or prohibition of certain outbound investments and other transactions by US persons involving persons of...more

Biden Administration Issues First-Ever National Security Memorandum on Artificial Intelligence

On October 24, 2024, President Biden issued the first-ever National Security Memorandum (NSM) on artificial intelligence (AI), fulfilling another directive (subsection 4.8) set forth in the Administration’s Executive Order on...more

Trends in US Cybersecurity Regulation

As cybersecurity rules proliferate, companies must navigate a maze of new, and often overlapping, proactive and reactive cybersecurity requirements and guidance. This Legal Update surveys new cybersecurity rules and...more

Department of Justice Issues Notice of Proposed Rulemaking to Regulate Export of Sensitive Personal Data

On October 21, 2024, the Department of Justice (DOJ) released an unpublished Notice of Proposed Rulemaking (NPRM), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by...more

US Department of Commerce Issues Proposal to Require Reporting Development of Advanced AI Models and Computer Clusters

On September 9, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (BIS) released notice of a proposed rule to create a mandatory reporting requirement for artificial intelligence (AI)...more

CFIUS Announces $60 Million Penalty and Debuts New Enforcement Website

On August 14, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) announced a $60 million penalty, “the largest penalty CFIUS has ever issued,” following its finding of material violations...more

US DoD Issues Class Deviation Delaying DFARS Implementation of Upcoming NIST SP 800-171, Revision 3

On May 2, 2024, the Department of Defense (DoD) issued a class deviation to DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting. The deviation relates to contractors’ compliance with...more

Commerce Considers ICTS-related Rules to Address Connected Vehicle Risks

On March 1, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (“BIS”) published an Advance Notice of Proposed Rulemaking1 (the “Notice”) seeking public comments on potential regulation of the...more

EU AI Act: European Parliament and Council Reach Agreement

On 9 December 2023, European Parliament negotiators and the Council presidency agreed on the final version of what is claimed to be the world's first-ever comprehensive legal framework on Artificial Intelligence; the European...more

SEC Adopts Final Rules on Public Company Cybersecurity Disclosures of Incidents and Processes

Background and Summary - Table On July 26, 2023, the U.S. Securities and Exchange Commission (the “SEC”) issued a release (the “Adopting Release”), adopting final rules (the “Final Rules”) aimed at standardizing and...more

Blackbaud Inc. to Pay $3 Million to SEC for Alleged Misleading Disclosures in 2020 Ransomware Attack

On March 9, 2023, the Securities and Exchange Commission (“SEC”) announced that Blackbaud Inc. (“Blackbaud”) agreed to pay $3 million to settle charges for alleged misleading disclosures about its 2020 ransomware attack and...more

The Cyber Executive Order: Key Takeaways for Businesses

With high-profile cybersecurity incidents hitting the headlines, President Biden’s recent cybersecurity executive order seeks to strengthen security practices at federal agencies and government contractors. But what does the...more

President Biden Issues National Security Memorandum on Critical Infrastructure Cybersecurity

On July 28, 2021, President Biden signed a national security memorandum that seeks to “significantly improve” the cybersecurity of critical infrastructure systems....more

Critical Pipeline Cybersecurity Directive Released

In the wake of the May 2021 ransomware attack on a major US oil pipeline, the Department of Homeland Security’s (DHS) Transportation Security Administration (TSA) has released a security directive (the “TSA Directive”) to...more

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