News & Analysis as of

Data Security Compliance Enforcement Actions

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

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Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

The Volkov Law Group

Episode 366 -- DOJ Issues Data Security Program Requirements

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Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

Sheppard Mullin Richter & Hampton LLP

DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S....

The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal...more

Davis Wright Tremaine LLP

DOJ Issues Guidance on Foreign Data Access Rule, Announces Conditional 90-Day Enforcement Pause for "Good Faith Efforts"

The Department of Justice (DOJ) has issued guidance on its recently effective rule targeting foreign adversaries that "use commercial activities to access, exploit, and weaponize U.S. Government-related data and Americans'...more

Mayer Brown

Department of Justice Releases Compliance & Enforcement Guidance on Data Security Program

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On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...more

Cozen O'Connor

NY Settles With Insurer on Data Breach Rooted in Security Deficiencies

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New York AG Letitia James settled with Root Insurance Company to resolve allegations that the company’s data security deficiencies led to a 2021 data breach involving 72,000 people, in violation of state consumer protection...more

A&O Shearman

Hong Kong passes its first Cybersecurity Law to safeguard critical infrastructure

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Hong Kong’s Legislative Council passed the Protection of Critical Infrastructures (Computer Systems) Bill (the “CI Bill”) on March 19, 2025. This landmark legislation aims to enhance cybersecurity and minimize disruptions...more

Foley Hoag LLP - Security, Privacy and the...

HHS OCR Settles HIPAA Security Rule Investigation with Health Fitness Corporation

On March 21, 2025, the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) announced a settlement of HIPAA security rule claims involving Health Fitness Corporation (Health Fitness). Health Fitness...more

Baker Botts L.L.P.

Ninth Circuit Upholds Conviction of Former Uber Security Chief Joseph Sullivan in Connection with 2016 Uber Data Security Breach

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On March 13, 2025, a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit unanimously upheld the conviction of former Uber Chief Security Officer Joseph Sullivan. The ruling affirms Sullivan’s 2022 conviction...more

Nilan Johnson Lewis PA

Nine Steps Healthcare Entities Should Take to Prevent Cyberattacks

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The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently imposed a $1.5 million civil money penalty against Warby Parker, Inc., a manufacturer and online retailer of eyewear, for...more

Bradley Arant Boult Cummings LLP

Looking Back at the False Claims Act in 2024 as the Government Keeps its Sights on Cybersecurity in 2025

In 2024, the government and whistleblowers were party to 558 settlements and judgments collecting over $2.9 billion. The government continued its effort to combat cybersecurity threats through its Civil Cyber-Fraud...more

Venable LLP

The Biden/Chopra CFPB's 2025 Guidance Compendium: A Last Gasp or Lasting Legacy?

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On the eve of a change in administration, the Biden/Chopra CFPB released a "Compendium of Recent CFPB Guidance," a sweeping collection of interpretations of federal consumer financial laws under the current leadership...more

Alston & Bird

FTC Announces Proposed Settlement with GoDaddy Incorporating Prescriptive Cybersecurity Requirements

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On January 15, 2025, the Federal Trade Commission (FTC) announced a proposed settlement with GoDaddy Inc. (GoDaddy) for making false or misleading representations about their security practices in violation of Section 5 of...more

Health Care Compliance Association (HCCA)

With Nod to OCR, Indiana Inks $350K Deal With Dental Firm Following Hack

Recent federal enforcement actions have brought home the lesson that there’s really no acceptable reason for denying a patient timely access to medical records. Last year, for example, the HHS Office for Civil Rights (OCR)...more

Hogan Lovells

Slew of OCR activity underscores agency’s focus on security and AI

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Recent enforcement actions, audit activity, proposed rulemakings, and guidance issued by the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) highlight the agency’s focus on health data...more

Smith Anderson

Preparing for Data Privacy Expansion in 2025: Is Your Business Ready?

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As we step into 2025, data privacy laws in the United States are evolving rapidly. With eight new state privacy laws taking effect, businesses face an increasingly complex web of compliance obligations—even in states without...more

Constangy, Brooks, Smith & Prophete, LLP

Garden State, are you ready for the NJ Data Privacy Act?

The NJ Data Privacy Act takes effect tomorrow. The New Jersey Data Privacy Act is set to take effect tomorrow, January 15. The NJDPA was signed into law by Gov. Phil Murphy (D) on January 16, 2024. The NJDPA is similar to...more

Saul Ewing LLP

Two CMPs and One Settlement Close Out 2024 HIPAA Enforcement

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December 2024 was an active month for the U.S. Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR"). OCR announced (i) a $1.19 million civil monetary penalty ("CMP") against Gulf Coast Pain...more

American Conference Institute (ACI)

[Event] 2nd National Conference on Cybersecurity Law & Compliance - January 29th - 30th, Arlington, VA

Cyberattacks are affecting every company and sector. Meanwhile, the regulatory landscape is intensifying as the SEC continues to enforce the cyber-risk management disclosure rules. Every day presents a new compliance and...more

Robinson+Cole Data Privacy + Security Insider

A Year in Privacy and Security: Privacy Violations, Large-Scale Data Breaches, and Big Fines and Settlements

2024 was a year chock-full of data breaches and privacy violations. Many new data privacy and cybersecurity regulations were introduced (and became effective), and regulators sent a strong message to businesses that privacy...more

Health Care Compliance Association (HCCA)

Penn State, GA Tech Cybersecurity Cases Join 10 Others FCA Attorney Has Under Seal

Note to research compliance officials still digesting news of Pennsylvania State’s recent $1.25 million settlement over False Claims Act (FCA) allegations related to cybersecurity and the government’s recent intervention in a...more

Saul Ewing LLP

No “Trick”: Plastic Surgery Practice Agrees to Pay a $500,000 HIPAA Settlement Following Ransomware Attack

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On October 31, 2024, the U.S. Department of Health and Human Services (“HHS”), Office of Civil Rights (“OCR”) announced a $500,000 settlement with Plastic Surgery Associates of South Dakota (“PSA”) concerning potential...more

Gray Reed

Constructing Compliance: What the Construction Industry Needs to Know about the Texas Data Privacy and Security Act

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The Texas Data Privacy and Security Act (TDPSA) is now in full effect, and this comprehensive legislation establishes stringent mandates on how consumer-related personal data of Texas residents should be collected, used,...more

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