Cybersecurity, Department of Justice (DOJ), International Emergency Economic Powers Act (IEEPA)

DOJ Issues Final Rule Targeting Foreign Access to Americans’ Sensitive Data

Davis Wright Tremaine LLP on 1/7/2025

The U.S. Department of Justice (DOJ) has issued a comprehensive final rule (the "Rule") targeting foreign access to sensitive U.S. data, including Americans' "bulk" sensitive personal data....more

DOJ and CISA Propose New National Security Program to Regulate Foreign Access to Sensitive Data

Wiley Rein LLP on 10/24/2024

On October 21, 2024, the U.S. Department of Justice (Department or DOJ) and the U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) issued proposals – required by the...more

Operational Implications of the New Bulk Sensitive Data Executive Order

Ankura on 5/7/2024

On February 28, 2024, President Biden signed Executive Order 14117 (the EO), on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The United...more

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

Morrison & Foerster LLP on 4/30/2024

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Public Company Watch: March 2024

Paul Hastings LLP on 3/28/2024

In the March edition of our Public Company Watch, we cover key issues impacting public companies, including the new climate disclosure rules, SEC scrutiny on beneficial ownership filings, West Palm Beach Firefighters’ Pension...more

The North Korean Crypto Threat

K2 Integrity on 10/17/2022

Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Treasury Actions to Counter Ransomware

Orrick, Herrington & Sutcliffe LLP on 10/13/2021

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

White House Issues Open Letter to Private Businesses Regarding the Threat of Ransomware

Foley & Lardner LLP on 6/14/2021

On June 2, 2021, Anne Neuberger, Deputy Assistant to the President and Deputy National Security Advisor for Cyber and Emerging Technology, published a rare open letter to the corporate executives and business leaders of...more

Virtual Currency as a Threat to National Security?

King & Spalding on 3/12/2020

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more