News & Analysis as of

Data Security New Guidance Enforcement Actions

Porter Hedges LLP

DOJ Issues Data Security Program Compliance Guide

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On April 11, 2025, the U.S. Department of Justice’s National Security Division (NSD) issued a Compliance Guide to provide additional information to assist companies and individuals in complying with the NSD’s Data Security...more

Faegre Drinker Biddle & Reath LLP

DOJ Releases New Key Guidance on Its Data Security Program (DSP)

On April 11, 2025, the National Security Division (NSD) of the Department of Justice issued a press release (Press Release) that outlines its approach to implementing and enforcing the DOJ’s recent final rule on “Preventing...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

Mayer Brown on

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

Dorsey & Whitney LLP

DOJ Limits Enforcement During First 90 Days of US-China Data Export Rules

Dorsey & Whitney LLP on

In a Press Release issued April 11, 2025, the U.S. Department of Justice (“DOJ”) indicated that it would prioritize “facilitating compliance” over civil enforcement actions for the first 90 days of its new US-China data...more

Sheppard Mullin Richter & Hampton LLP

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

BakerHostetler

OCR’s October Initiatives: Strengthening Telehealth Security and HIPAA Compliance

BakerHostetler on

October has been a busy month for the OCR, which is tasked with enforcing the regulations issued under HIPAA. In the past week, the OCR released two new guidance documents aimed at reducing the privacy and security risks...more

Akin Gump Strauss Hauer & Feld LLP

Vermont Attorney General Provides Guidance on Security Breach Notice Act

On March 5, 2020, Gov. Phil Scott (VT-R) signed into law amendments to the Security Breach Notice Act (the “Act”). The amendments, which originated in the State Senate as part of an initiative addressing a number of data...more

Shook, Hardy & Bacon L.L.P.

Privacy and Data Security Alert | December 2019

SDNY Rejects Standing under “Increased Risk” Theory Where Data Not Targeted or Stolen - The Southern District of New York rejected a settlement that would have resolved a class action based on the unauthorized (and...more

Latham & Watkins LLP

Financial Firms Beware: Dangers Lurk in the Cloud

Latham & Watkins LLP on

US regulators are calling attention to financial firms’ obligations to protect against evolving cybersecurity threats. On October 2, 2019, the Financial Industry Regulatory Authority (FINRA) issued an information notice to...more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

Moore & Van Allen PLLC on

As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

Holland & Knight LLP

SEC Issues New Cybersecurity Guidance; Makes Clear that Cybersecurity Disclosures Are Part of Existing SEC Requirements - Guidance...

Holland & Knight LLP on

On Feb. 21, 2018, the Securities and Exchange Commission (SEC) issued interpretive guidance on its expectations for corporate disclosures on cybersecurity risks. The guidance delineates where it believes existing SEC rules...more

Snell & Wilmer

“Stick With Security” - Getting Up to Speed With the FTC’s New Initiative

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Companies that have experienced data breaches or security hacks have subsequently found themselves the subject of enforcement actions by the Federal Trade Commission (“FTC”) for violating the FTC Act, due to inadequate...more

Proskauer on Privacy

SEC Cybersecurity Update

Proskauer on Privacy on

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Morrison & Foerster LLP

The Russian Data Protection Authority, Roskomnadzor, Enforces New Russian Data Localization Law

On September 9, 2015, the Federal Service for Supervision of Communications, Information Technology and Mass Communications (the “Roskomnadzor”) reported on its website that it blocked an extensive online database of more...more

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