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In this episode of "Regulatory Phishing," Government Contracts and Cybersecurity attorney Eric Crusius delves into the latest developments from the Cybersecurity Maturity Model Certification (CMMC) program, National Institute...more
The Ministry of Public Security and the Cyberspace Administration of China (CAC) on July 26, 2024 released an announcement soliciting public comments on the Draft Measures for the Administration of National Network Identity...more
On July 5, the California Privacy Protection Agency (CPPA) issued its NPRM to amend sections of the Delete Act. As covered by InfoBytes here, the Delete Act was signed into law in 2023 as SB 362 and transferred the...more
The Cybersecurity and Infrastructure Agency (CISA) is seeking comment on a proposed rule to implement reporting requirements for critical infrastructure entities, including health care entities, on cyberattacks and ransomware...more
Most businesses in the United States will have to file incident reports—including for ransomware payments—under the Proposed Rule. The Department of Homeland Security has the authority to issue subpoenas and even penalties...more
Although not yet the subject of the formal rulemaking process, the California Privacy Protection Agency (the “CPPA”) has released draft proposed regulations for cybersecurity audits required by Section 1798.185(a)(15)(A) of...more
On March 27, 2024, the Cybersecurity & Infrastructure Security Agency (“CISA”) released proposed regulations requiring expansive new cybersecurity incident and ransomware payment reporting across sixteen “critical...more
After years of internal discussion, the Board of the California Privacy Protection Agency (CPPA), at their March 8th meeting, voted to progress toward formalizing the proposed regulations on risk assessments and automated...more
The EU AI Act, which was passed by the European Parliament on 13 March and is set to become law later this year, will probably be the world’s first legislation to introduce a general regulatory framework for artificial...more
Volume 4, Issue 2, 2024 Welcome! Welcome to the second issue of Promissory Notes - our banking and finance e-newsletter - for 2024. Business today is characterized by relentless change. To assist our clients in navigating...more
On February 28, 2024, U.S. President Joe Biden issued Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (EO), which authorizes...more
The Department of Health and Human Services ("HHS") has released voluntary cybersecurity performance goals for the health care and public health sectors, which outline an increasingly standardized regulatory approach and...more
Welcome to the Data Privacy and Cybersecurity chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Amendments to key rules and regulations will take effect in 2024,...more
On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more
The Food and Drug Administration (FDA) is seeking strategies from Jeffrey W. Taub, M.D., to prevent future violations of human subject regulations the agency said were documented during site visits in September and October...more
The European Union (EU) is poised to enact the Cyber Resilience Act (CRA), a comprehensive cybersecurity regulation with major implications for software and connected device manufacturers in the United States and globally....more
If the penultimate enforcement settlement of 2023 issued by the HHS Office for Civil Rights (OCR) sounds familiar, that’s with good reason. And the last one of the year should ring some bells, too....more
New York has released proposed cybersecurity regulations for hospitals. The regulations, which were published in The State Register on Dec. 6 and will undergo a 60-day public comment period ending on Feb. 5, are designed to...more
Hospitals, health systems and providers are targets of cyberattacks at an alarming rate, putting patient data, electronic infrastructure and, most importantly, patient lives at risk. The Department of Health and Human...more
On December 8, 2023, the California Privacy Protection Agency (CPPA) Board discussed a draft of its forthcoming artificial intelligence (AI) regulations on automated decision making technology (ADMT). The proposed...more
Over the last two years, the Office for Civil Rights (“OCR”) has released a number of proposed regulations and new guidance relating to the HIPAA privacy rules. Not to be left out, recently, the Federal Trade Commission...more
The California Privacy Protection Agency (“CPPA”) published a revised set of Draft Cybersecurity Audit Regulations ahead of the CPPA Board’s December 8, 2023 meeting. When the CPPA Board met on December 8, several key...more
Substantial changes to the California Consumer Privacy Act (CCPA) are coming soon through five sets of proposed regulations governing (1) cybersecurity audits, (2) privacy risk assessments, (3) artificial...more
On November 27 2023, the California Privacy Protection Agency (“CPPA”) released the first draft of its automated decision-making (“ADMT”) rules (the “Draft Rules”) for those covered entities that must comply with the...more
In the run-up to this Friday’s December Board meeting, the California Privacy Protection Agency (CPPA or the “Agency”) has continued its recent flurry of regulatory activity. Late last week, the CPPA published an additional...more