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WilmerHale

Cybersecurity in the First 100 Days

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This week, the Trump Administration reached the 100-day mark—a significant milestone in any presidential term wherein key administrative priorities and objectives are promulgated. Perhaps unsurprisingly, cybersecurity stands...more

Wiley Rein LLP

Update: DOJ and CISA Issue New National Security Program to Regulate Foreign Access to Sensitive Data

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On January 8, 2025, the U.S. Department of Justice (Department or DOJ) issued new rules required by then-President Biden’s February 2024 Executive Order (EO) 14117 to establish a new regulatory framework aimed at “Preventing...more

Akin Gump Strauss Hauer & Feld LLP

Preserving and Protecting the Integrity of American Elections (Trump EO Tracker)

Enforce the Federal prohibition on foreign nationals voting in Federal elections. Requires documentary proof of United States citizenship and for verification from a State or local official for national mail voter...more

Wiley Rein LLP

New DOJ Restrictions on Cross-Border Data Transactions Take Effect April 8: Ten Questions as Your Business Prepares to Comply

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The U.S. Department of Justice’s (DOJ) sweeping new rule on cross-border data transactions is set to take effect in substantial part next month, with broad implications for companies that transfer U.S. personal data or...more

King & Spalding

DOJ Issues Final Rule Restricting Foreign Access to U.S. Data

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The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies. On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more

Wiley Rein LLP

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

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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

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

Paul Hastings LLP

FBI, DOJ, and SEC Publish Guidance on Requesting Delayed Reporting of Item 1.05, Material Cybersecurity Incidents, on Form 8-K

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On July 26 2023, the Securities and Exchange Commission (SEC) adopted final rules intended to enhance and standardize disclosures of cybersecurity risk management, strategy, governance, and incident reporting by public...more

Hogan Lovells

Agencies issue guidance on delayed SEC reporting of material cybersecurity incidents - SEC Update

Hogan Lovells on

Since December 18, 2023 public companies other than smaller reporting companies are required to report a cybersecurity incident under Item 1.05 of Form 8-K within four business days after the company determines the incident...more

Faegre Drinker Biddle & Reath LLP

DOJ & FBI Issue New Guidelines for Delayed Reporting of Cyber Incidents to the SEC

Under the Securities and Exchange Commission’s (SEC) new Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule (cybersecurity rule), public companies subject to the cybersecurity rule must promptly...more

Paul Hastings LLP

Public Company Watch: December 2023

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In the December Public Company Watch, we cover key issues impacting public companies, including a preview of the SEC’s latest regulatory agenda, an update regarding the Fifth Circuit vacating the SEC’s share repurchase rules,...more

Skadden, Arps, Slate, Meagher & Flom LLP

FBI, DOJ and SEC Publish Guidance on Requesting Delayed Reporting of Material Cyber Incidents on Form 8-K: Takeaways for CISOs and...

The U.S. Securities and Exchange Commission (SEC) adopted final rules in 2023 that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and incident reporting by...more

Wiley Rein LLP

SEC Breach Reporting Rules Effective as of December 18

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For most filers, the U.S. Securities and Exchange Commission’s (SEC) new Form 8-K rules for reporting material cybersecurity incidents took effect yesterday, December 18, 2023. The rule has been controversial and created some...more

Wilson Sonsini Goodrich & Rosati

FBI, DOJ, and SEC Provide Guidance and Requirements for Requests to Delay Form 8-K Disclosures for Material Cybersecurity...

As discussed in a previous alert, on July 26, 2023, the U.S. Securities and Exchange Commission (SEC) approved final rules requiring that public companies report information regarding cybersecurity incidents within four...more

Wilson Sonsini Goodrich & Rosati

New Guidance on Delayed Disclosure of Material Cybersecurity Incidents

As a follow up to yesterday’s post, our recent Client Alert discusses new guidance from the FBI, DOJ, and SEC on requesting a delay to Form 8-K disclosures for material cybersecurity incidents that pose a substantial risk to...more

Mayer Brown

DOJ and FBI Announce Guidance on Seeking Delays in SEC 8-K Filings for Cyber Incidents

Mayer Brown on

On December 12, 2023, the Department of Justice (DOJ) issued guidelines for companies to follow in requesting that the Attorney General authorize delays of cyber incident disclosures required by the U.S. Securities and...more

Wiley Rein LLP

SEC Cyber Reporting Mandates: How to Request a National Security or Public Safety Delay

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On December 18, the Securities and Exchange Commission's (SEC) new disclosure requirements go into effect and will require public companies to publicly report material cybersecurity incidents within four days of making a...more

Bass, Berry & Sims PLC

Cyber Incident Reporting May Be “Material” for Federal Contractors

Bass, Berry & Sims PLC on

Last month, the Federal Acquisition Regulatory Council proposed new cybersecurity and incident reporting regulations for federal contractors on behalf of the Department of Defense (DoD), the General Services Administration...more

Akin Gump Strauss Hauer & Feld LLP

Government Contractors Beware: New Cybersecurity Rules and False Claims Act Enforcement Actions on the Rise

Two years after the Department of Justice (DOJ) established its Civil-Cyber Fraud Initiative, there has been a recent uptick in enforcement and regulatory activity related to cybersecurity. September opened with the unsealing...more

King & Spalding

Proposed FAR Revisions Aim to Standardize Cybersecurity Requirements Across Agencies and Add Incident Reporting Obligations for...

King & Spalding on

On October 3, the Department of Defense, General Services Administration, and the National Aeronautics and Space Administration published two sets of proposed revisions to the Federal Acquisition Regulation (“FAR”) pertaining...more

Wilson Sonsini Goodrich & Rosati

New Proposed Rules Published for Cyber Incident Reporting and Cybersecurity Requirements Will Have Major Impacts on Federal...

Reflective of the Government’s increasing focus on cybersecurity, on October 3, 2023, the Federal Acquisition Regulation Council (FAR Council) released two new proposed rules that will have major impacts on federal...more

Latham & Watkins LLP

Recent Developments for Directors - October 2023 Edition

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SEC Adopts Final Rules on Cybersecurity Disclosures - The SEC has adopted rules requiring companies to provide disclosure within four business days of determining that a material cybersecurity incident has occurred, and...more

Husch Blackwell LLP

Twelve Planning Tips to Avoid Complications with the SEC’s Cybersecurity Disclosure Rules: Part III

Husch Blackwell LLP on

Key Point: The decision making processes to determine whether a cybersecurity incident is material or not, should include documenting the factors behind each determination and should be practiced before an incident occurs. ...more

Gardner Law

Transatlantic Legal-Regulatory Update: Live from the Heart of Silicon Valley

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US and EU Life Sciences Law firms Fieldfisher & Gardner Law recently held a CLE event in Silicon Valley covering Healthcare Compliance, Data Privacy and Regulatory hot topics for MedTech and Pharma companies. Discussion...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

CISA Announces New Binding Operational Directive to Manage Federal Civilian Agency Threats

Takeaway: The latest directive from CISA will enhance federal agencies’ ability to identify vulnerabilities in their networks to prevent and respond to cybersecurity incidents....more

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