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Reporting Requirements Information Technology

Guidepost Solutions LLC

Unlocking Opportunity: Navigating the New Data Center Validated End User Program

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a significant interim final rule (IFR) that has created both challenges and exciting opportunities for these operators. This IFR...more

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

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On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

Mayer Brown Free Writings + Perspectives

FINRA Publishes 2025 Annual Regulatory Oversight Report

The Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2025 FINRA Annual Regulatory Oversight Report (the “Report”), which builds on the structure and content of FINRA’s prior reports for 2021-2024. This...more

Ropes & Gray LLP

Capital Markets & Governance Insights - January 2025

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Companies should not minimize the extent of a material cybersecurity incident by omitting material facts regarding the scope and potential impact of the incident. Cybersecurity risk factor disclosures should be tailored to a...more

A&O Shearman

EU joint report on the feasibility for further centralization of reporting of major ICT-related incidents

A&O Shearman on

The European Supervisory Authorities have published a joint report on the feasibility of further centralization of the reporting of major ICT-related incidents by financial entities to competent authorities. The ESAs' joint...more

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

Troutman Pepper Locke

6 Considerations to Determine if a Cyber Incident Is Material

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In late June, the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance released five new compliance and disclosure interpretations regarding the disclosure of material cybersecurity incidents...more

Latham & Watkins LLP

FCA Issues Discussion Paper on Changes to the UK Transaction Reporting Regime

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IT teams will want to contribute to the debate over the FCA’s proposed changes, which could introduce additional complexities and lead to major IT costs for firms....more

Wyrick Robbins Yates & Ponton LLP

Living in a Material World: SEC Clarifies Expectations Regarding Form 8-K Disclosure of Material Cybersecurity Incidents

Last month, the Director of the Division of Corporation Finance (“Director”) of the Securities and Exchange Commission (“SEC”) issued new guidance regarding disclosures of material cybersecurity incidents via Form 8-K under...more

Health Care Compliance Association (HCCA)

Privacy Briefs: April 2024

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

Hinckley Allen

Navigating Profound Change: CISA Announces Proposed Rule for Mandated Cyber Incident Reporting

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In 2025, new federal reporting requirements will require hundreds of thousands of organizations to report cyber incidents within hours of discovery to the United States Government, marking a significant impact on how...more

Sheppard Mullin Richter & Hampton LLP

CISA Cyber Incident Reporting for Critical Infrastructure Will Significantly Impact Government Contractors, Suppliers, and Service...

The Cybersecurity and Infrastructure Security Agency (“CISA”) recently released its new Proposed Rule pursuant to the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which was published in the...more

Paul Hastings LLP

Key Takeaways from SEC Speaks 2024 Event

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Last week, Paul Hastings attended the Securities and Exchange Commission (SEC) Speaks 2024 event presented by the Practising Law Institute (PLI) in cooperation with the SEC on April 1 and 2. The SEC Speaks program provides...more

Paul Hastings LLP

CISA Proposes Sweeping Cybersecurity Incident Reporting for U.S. Companies

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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

Guidepost Solutions LLC

Unlocking the Power of Precision: Data Quality and Accessibility for Corporate Security Departments

Amidst the relentless waves of pandemic-induced uncertainty, organizations found themselves at a crossroads, compelled to reimagine how their businesses operated. For example, when stay at home orders continued to be extended...more

Burr & Forman

Cyber Incident Reporting Obligations for Public Companies under the SEC’s New Cybersecurity Rules

Burr & Forman on

The U.S. Securities Exchange Commission (SEC) recently adopted a final rule regarding cybersecurity risk management, governance, and incident reporting. The final rule went into effect on September 5, 2023, and disclosure...more

Health Care Compliance Association (HCCA)

Privacy Briefs: February 2024

The American Hospital Association (AHA) has warned that information technology (IT) help desks are being targeted in a social engineering scheme that uses the stolen identity of revenue cycle employees or employees in other...more

Fenwick & West LLP

New Federal Requirements for AI and IT System Implementation in Healthcare

Fenwick & West LLP on

On October 30, 2023, the Biden administration issued Executive Order 14110 on the Safe, Secure and Trustworthy Development and Use of Artificial Intelligence (the “Executive Order”). As detailed in our previously published...more

Polsinelli

The SEC Raises the Stakes: New Cybersecurity Rules for Publicly Traded Companies Hit the Books in 2023

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In 2023, the U.S. Securities and Exchange Commission (“SEC”) issued its now-fully implemented Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure Rule. The Rule reflects the reality that cybersecurity...more

Skadden, Arps, Slate, Meagher & Flom LLP

Exits, Ring-Fencing and Other Risk Management Strategies for Multinationals Operating in Geopolitically Volatile Areas

With mounting geopolitical tensions, multinationals face a very real and immediate risk of being deprived of profits, control or even ownership of some wholly or partially owned local businesses. As a result, business leaders...more

White & Case LLP

The SEC’s Charges Against SolarWinds and its Chief Information Security Officer Provide Important Cybersecurity Lessons for Public...

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On October 30, 2023, the US Securities and Exchange Commission ("SEC") announced that it filed charges against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer ("CISO") in connection...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

McDermott Will & Emery

Special Report - A Million Reasons to Share: OIG’s Final Rule on Information Blocking Enforcement

McDermott Will & Emery on

On July 3, 2023, the US Department of Health and Human Services Office of Inspector General (OIG) published its long-awaited final rule implementing the 21st Century Cures Act provisions authorizing OIG to investigate claims...more

Sheppard Mullin Richter & Hampton LLP

NIST Releases Initial Public Draft of NIST SP 800-171, Revision 3 for Protection of Sensitive Government Information

The National Institute of Standards and Technology (NIST) has released an initial public draft of NIST SP 800-171, Revision 3, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations. Compliance...more

Polsinelli

Cyber Incident Reporting for Critical Infrastructure Act: Significant Changes to Incident Reporting Are on the Horizon

Polsinelli on

In May 2021, Colonial Pipeline, a privately held oil pipeline responsible for nearly half of the oil supply for the U.S. East Coast, was crippled by a DarkSide ransomware attack. DarkSide is widely believed to be a...more

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