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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

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding and Mitigating Legal and Compliance Risks Relating to Cartels and Transnational Criminal Organizations

On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more

Foley & Lardner LLP

Executing Audit Committee Oversight in Turbulent Times: Risk Management and Financial Reporting

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Foley & Lardner LLP recently sponsored NACD Northern California’s “Executing Audit Committee Oversight in Turbulent Times: Risk Management and Financial Reporting” dinner. Foley partners Sandy Winer, Lauren Valiente, and Nick...more

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

BakerHostetler

Weekly Blockchain Blog - July 2024 #2

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US Stablecoin Companies Achieve Licenses, Avoid SEC Enforcement Action - According to a recent press release, Circle, the issuer of USDC and EURC, announced that it is now the “first global stablecoin issuer to achieve...more

A&O Shearman

Announcement of new DOJ Whistleblower Policy

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...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

Public Company Watch: January 2024

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In the January Public Company Watch, we cover key issues impacting public companies, including navigating the 2023 20-F season, updated SEC guidance related to confidential treatment applications, the Delaware Court of...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

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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

Paul Hastings LLP

Public Company Watch: November 2023

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In the November edition of our Public Company Watch, we cover key issues impacting public companies, including how to prepare for the 2024 10-K season; the SEC announcing a new intake system for Rule 14a-8 submissions; the...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

Proskauer Rose LLP

Countdown to Transparency: Beneficial Ownership Reporting

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In 2021, the U.S. enacted the Corporate Transparency Act (the “CTA”) as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the Treasury’s Financial...more

Husch Blackwell LLP

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

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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

Eversheds Sutherland (US) LLP

Financial Crime Horizon Scanner: 2022 - Q1 (US)

Our quarterly Financial Crime Horizon Scanner for the US summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources. We hope that you...more

Perkins Coie

Answers to Common Questions Regarding New CIRCIA

Perkins Coie on

President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The enactment of CIRCIA follows attacks on critical infrastructure, such as the May 2021...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

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In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

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