News & Analysis as of

Enforcement Cybersecurity

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - December 2nd - 5th, 8:00 am - 5:00 pm CT

Learn the key principles of compliance - no travel required! If you’re new to or have minimal experience in compliance management don’t miss this opportunity to build the foundational knowledge you need! SCCE’s four-day...more

Harris Beach PLLC

First Patch in AI Quilt: Colorado Passes Nation’s 1st Broad AI Law

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As Artificial Intelligence becomes more of a household name, lawmakers and regulators throughout the nation are examining ways to protect consumers. Colorado recently passed first-of-its-kind legislation, a comprehensive law...more

Foley & Lardner LLP

Down But Not Out: Federal Court Curbs SEC Cybersecurity Enforcement Authority

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In a stinging rebuke of its attempted cybersecurity-related enforcement against a public company, a federal judge recently dismissed most of the charges that the U.S. Securities and Exchange Commission (SEC) had filed against...more

Foley & Lardner LLP

DOJ Shows its Commitment to Cybersecurity Enforcement Through the False Claims Act

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At one time, False Claims Act (FCA) investigations and enforcement actions were largely focused on health care and defense contracts. While those two areas continue to dominate the FCA landscape, cybersecurity has emerged as...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

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Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

A&O Shearman

Judge Dismisses Most Of SEC’s Suit Against An IT Management Software Company Over Cybersecurity Disclosures

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On July 18, 2024, U.S. District Judge Paul Engelmayer of the U.S. District Court for the Southern District of New York issued a comprehensive 107-page opinion that may have significant implications for the Securities and...more

Kohn, Kohn & Colapinto LLP

Defense Contracting, Cybersecurity and COVID: Major Qui Tam Settlements from June 2024

In June, the U.S. Department of Justice (DOJ) announced several major False Claims Act (FCA) settlements stemming from qui tam whistleblower lawsuits. Under the FCA’s qui tam provisions, whistleblowers have the power to...more

Arnall Golden Gregory LLP

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more

Jenner & Block

Client Alert: The SEC’s Approach to Cybersecurity Disclosure Decisions

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The SEC’s Director of Corporation Finance, Erik Gerding, recently issued two statements regarding a public company’s disclosure obligations in response to a cybersecurity incident. These remarks follow the adoption of the...more

Clark Hill PLC

A Cautionary AI Tale for Federal Contractors

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Much has been and will be written on responsibility determinations and compliance programs in federal contracting, particularly at the intersection of cybersecurity and recent developments. Although a federal contract is not...more

Foley & Lardner LLP

SEC Tightens Cybersecurity Requirements with Regulation S-P Amendments

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Share on Twitter Print Share by Email Share Back to top “The basic idea for covered firms is if you’ve got a breach, then you’ve got to notify. That’s good for investors.” Those were among the remarks that U.S. Securities and...more

Clark Hill PLC

Right To Know - June 2024, Vol. 18

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Cyber, Privacy, and Technology Report - Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed....more

Mintz - Antitrust Viewpoints

Senators Advance Three Election-Related AI Bills Out of Committee — AI: The Washington Report

In May 2024, the Senate Rules and Administration Committee advanced three bills sponsored by Chair Amy Klobuchar (D-MN) on elections and AI out of committee. These bills include provisions that would prohibit deceptive AI...more

Perkins Coie

Securities Enforcement Forum West 2024: SEC Reinforces Cooperation Requirements and Enforcement Priorities

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Senior Division of Enforcement officials from the U.S. Securities and Exchange Commission (SEC) spoke with SEC alumni, private practitioners, and other professionals in the field at the Securities Enforcement Forum West 2024...more

Porter Hedges LLP

Best Practices to Ensure Compliance with Upcoming Data Protection Regulations

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The Department of Justice ("DOJ") is wasting no time in implementing the new cyber-security Executive Order (the EO), signed on February 28, 2024. As explained in our April 2024 blog post, the EO aims to portect Americans’...more

Davis Wright Tremaine LLP

SEC Clarifies Reporting of Material vs. Immaterial Cybersecurity Incidents

The U.S. Securities and Exchange Commission's (SEC) Division of Corporate Finance (Division) published a statement on May 21, 2024, regarding how public companies may disclose cyber incidents they determined to be immaterial....more

Goldberg Segalla

EPA Enforcement Alert: It’s Critical for Community Water Systems to Review Cybersecurity Protections

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The Environmental Protection Agency earlier this week issued an enforcement alert, explaining cybersecurity threats and vulnerabilities to community drinking water systems (CWSs) and actions needed by these systems in order...more

Davis Wright Tremaine LLP

FTC Finalizes Expansion of Health Breach Notification Rule's Broad Applicability to Unauthorized App Disclosures

The FTC issued a final rule to lock in changes to the Health Breach Notification Rule (HBNR) that it proposed in May 2023. While the HBNR began as a breach notification rule seemingly focused on a narrow set of applications...more

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

In Wake of Healthcare System Cyberattack, 22 State Attorneys General Call for Further Action of Data Privacy

On April 25, 2024, the attorneys general of 22 states issued a letter encouraging UnitedHealth Group and its subsidiary, Change Healthcare, to take additional steps to respond to a massively disruptive cyberattack. The broad,...more

Akin Gump Strauss Hauer & Feld LLP

New CISA Cybersecurity Incident Reporting Requirements Proposed for Critical Infrastructure Companies

On April 4, 2024, the Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) officially published its Notice of Proposed Rulemaking (NPRM) detailing significant new cybersecurity...more

Skadden, Arps, Slate, Meagher & Flom LLP

CPPA’s First Enforcement Advisory Focuses on Applying Data Minimization Principles to Consumer Requests

On April 2, 2024, the Enforcement Division of the California Privacy Protection Agency (CPPA) issued Enforcement Advisory No. 2024-01. This first-ever enforcement advisory focuses on promoting compliance with California...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - May 3rd, Lewis Center, OH

Looking for compliance education and networking in your area? SCCE & HCCA’s Regional Compliance & Ethics Conferences bring compliance practitioners from all disciplines together for convenient, local compliance education....more

Health Care Compliance Association (HCCA)

[Event] Regional Compliance & Ethics Conference - May 3rd, Lewis Center, OH

Looking for compliance education and networking in your area? SCCE & HCCA’s Regional Compliance & Ethics Conferences bring compliance practitioners from all disciplines together for convenient, local compliance education....more

Proskauer - The Capital Commitment

Cybersecurity Continues to be a Focal Point for Regulators in 2024

The SEC’s new and proposed rules on cybersecurity and cyber-incident reporting will have a dual impact on private investment advisers and funds. First, the proposal by the SEC will impose cybersecurity related...more

Bass, Berry & Sims PLC

CISA Publishes Proposed Rule for Cyber Reporting

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On April 4, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published its much-anticipated Notice of Proposed Rule Making for the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA)....more

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