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Cyber Attacks Reporting Requirements

Orrick, Herrington & Sutcliffe LLP

OCC announces major information security incident

On April 8, the OCC announced it had notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident involved unauthorized access to emails and their...more

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

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On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

DLA Piper

UK: Consultation on Ransomware payments

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On 14 January 2025, the UK Home Office published a consultation paper focusing on legislative proposals to reduce payments to cyber criminals and increasing incident reporting. ...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

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On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Integreon

Post-Breach Data Review: 5 Reasons Why You Should Not Go at It Alone

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After a data breach, organizations need to understand the scope of the incident in order to quickly resolve it and ensure they are able to meet notification requirements. The urgency often leads to the misguided belief that...more

Troutman Pepper Locke

6 Considerations to Determine if a Cyber Incident Is Material

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In late June, the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance released five new compliance and disclosure interpretations regarding the disclosure of material cybersecurity incidents...more

White & Case LLP

SEC Enforcement Heats up on Key Public Company Topics: Cyber Disclosure, Director Independence and Regulation FD

White & Case LLP on

The U.S. Securities and Exchange Commission's ("SEC") Division of Enforcement has recently brought a spate of enforcement actions relating to key topics for public companies. These include enforcement actions related to...more

HaystackID

[Webcast Transcript] Anatomy of a Business Email Compromise

HaystackID on

Editor’s Note: This webcast brings together some of HaystackID’s top experts to dissect the intricacies of Business Email Compromise (BEC) attacks—a rapidly growing threat impacting organizations globally. During the...more

Society of Corporate Compliance and Ethics...

The SEC’s cybersecurity and disclosure rules: The questions compliance pros still have

The U.S. Securities and Exchange Commission (SEC) Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rules officially went into effect in December 2023. Aimed at improving cybersecurity risk...more

Orrick, Herrington & Sutcliffe LLP

Proposed AI Reporting Requirements Tracking the Development of Foundational AI Models: Key Takeaways for Companies

The Commerce Department’s Bureau of Industry and Security (BIS) has proposed a rule that would establish reporting requirements to track development of advanced artificial intelligence (AI) models, in accordance with...more

Health Care Compliance Association (HCCA)

Privacy Briefs: September 2024

The HHS Centers for Medicare & Medicaid Services (CMS) and Wisconsin Physicians Service Insurance Corporation (WPS) are notifying 946,801 people whose protected health information or other personally identifiable information...more

DLA Piper

Australia: Anti-Scam Measures and Ransomware Reporting on the Agenda

DLA Piper on

Cyber regulation is changing in Australia. As governments globally grapple with the everchanging and increasingly challenging cyber landscape, Australia is poised to implement new laws and update existing regulation in order...more

Troutman Pepper Locke

SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

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I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

Davis Wright Tremaine LLP

California Legislature Sends Bills Regulating AI to the Governor

Last week, the California Legislature passed several bills that, if signed by the governor, will regulate how organizations develop, train, and use artificial intelligence (AI) models, systems, and applications. Of these...more

J.S. Held

Benefits of a vCISO in the Age of AI-Driven Cyberattacks

J.S. Held on

Cyberattacks powered by artificial intelligence have become more sophisticated as bad actors utilize machine learning to analyze vulnerabilities, automate exploits, and outpace traditional security measures. Through the use...more

Steptoe & Johnson PLLC

New York Federal Court Refuses to Extend Accounting Controls Requirements to Cybersecurity Controls

Section 13(b)(2)(B) of the Securities Exchange Act of 1934 requires public companies to “devise and maintain a system of internal accounting controls.” In a recent opinion, a New York federal court rejected the Securities...more

Skadden, Arps, Slate, Meagher & Flom LLP

Takeaways From the Dismissal of SEC Claims Against SolarWinds and Its CISO

The U.S. District Court for the Southern District of New York has dismissed many of the Securities and Exchange Commission’s (SEC’s) claims against software development company SolarWinds and its chief information security...more

Bradley Arant Boult Cummings LLP

Balancing Act: Industry Concerns Over CISA’s Proposed Cyber Incident Reporting Rule

As discussed in our previous blog post, the Cybersecurity and Infrastructure Security Agency (CISA) is proposing a significant new rule to bolster the nation’s cyber defenses through mandatory incident reporting. While...more

Alston & Bird

SEC Corporation Finance Provides Additional Guidance on the Disclosure of Material Cybersecurity Incidents in Form 8-K

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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

Cooley LLP

SEC charges RR Donnelley with control failures related to cybersecurity incident

Cooley LLP on

In this June Order, SEC Enforcement brought settled charges against R.R. Donnelley & Sons, a “global provider of business communications services and marketing solutions,” for control failures: more specifically, a failure to...more

Fenwick & West LLP

SEC Releases New 8-K CDIs for Item 1.05 - Cybersecurity Incidents

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On June 24, 2024, the SEC released five new CDIs on Material Cybersecurity Incidents. Please see a high-level summary below...more

Mayer Brown Free Writings + Perspectives

SEC Announces New Cybersecurity Interpretations

The SEC’s Division of Corporation Finance yesterday published five new Compliance and Disclosure Interpretations, or “C&DIs,” all concerning Item 1.05 of Exchange Act Form 8-K, Disclosure of Cybersecurity Incidents....more

Wyrick Robbins Yates & Ponton LLP

Living in a Material World: SEC Clarifies Expectations Regarding Form 8-K Disclosure of Material Cybersecurity Incidents

Last month, the Director of the Division of Corporation Finance (“Director”) of the Securities and Exchange Commission (“SEC”) issued new guidance regarding disclosures of material cybersecurity incidents via Form 8-K under...more

Jenner & Block

Client Alert: Takeaways from SEC v. SolarWinds Motion to Dismiss Hearing

Jenner & Block on

The SEC’s high-profile litigation against SolarWinds and its Chief Information Security Officer (CISO), Timothy Brown, reached a critical juncture on May 15, 2024, when the parties presented oral arguments before Judge Paul...more

Wilson Sonsini Goodrich & Rosati

SEC Expands Security and Breach Notification Requirements for Investment Firms

On May 16, 2024, the U.S. Securities and Exchange Commission (SEC) announced that it had adopted final amendments to its Regulation S-P (the Rule or Amended Rule), which governs “covered financial institutions’” treatment of...more

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