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

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

Trump EO on Preparedness and Resilience Could Signal Major Shifts in Federal Role

On March 19, 2025, the White House released Executive Order (EO) 14239, Achieving Efficiency Through State and Local Preparedness, which calls for a comprehensive review of and changes to many long-standing federal...more

CISA 2015 Reauthorization – Are Changes on the Horizon?

As we noted in Federal Cybersecurity Policy in 2025: What to Watch in Changing Times, key parts of the Cybersecurity Information Sharing Act of 2015 (CISA 2015), the United States’ foundational cybersecurity information...more

CYBER UPDATE: White House Seeks Regulatory Harmonization While Exploring a Pilot for Reciprocity Amid Proliferation of Regulations

Companies, particularly those in “critical infrastructure” sectors, have seen a dramatic increase in cybersecurity regulatory requirements in just the past few years – and the White House is looking to move faster. At the...more

New White House Policy Previews Increased Cybersecurity Oversight and Regulation

On April 30, 2024 the White House updated the foundational U.S. government policy that defines critical infrastructure (CI) sectors and establishes a coordination structure within the federal government to support owners and...more

DOJ Kicks Off Work to Regulate Foreign Access to Sensitive Personal Data Under New EO

On March 5, 2024, the Department of Justice (DOJ) issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern. The...more

Commerce Considers Regulating Connected Vehicles to Protect Against Foreign Adversaries

On March 1, 2024, at the direction of President Biden, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public comment on the proposed...more

SEC Breach Reporting Rules Effective as of December 18

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

Cyber Incident Reporting Guidance: DOJ Explains How It Will Determine if a Public Disclosure Poses Substantial National Security...

The cyber reporting landscape is rapidly shifting. Many agencies are developing rules, and a major player has been the U.S. Securities and Exchange Commission (SEC), with important questions arising about implementation of...more

Intelligence Gathering and FISA Section 702: Lots of Heat Obscures Important Practical Issues

As heated debate continues over possible changes to the Foreign Intelligence Surveillance Act (FISA), which is poised to expire later this month, we wanted to provide some perspective on a few practical issues. As former DOJ...more

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

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

National Cybersecurity Strategy Outlines A New Era of Cybersecurity Regulation

On March 2, 2023, the White House Office of the National Cyber Director (ONCD) released the National Cybersecurity Strategy (“Strategy”). The Strategy outlines the Administration’s priorities for cyber regulations and policy....more

White House Pivots on Cyber: Voluntary Compliance Carrots Are Being Replaced By Big Regulatory Sticks

The White House released the long-anticipated National Cybersecurity Strategy on March 2, 2023 setting out five (5) pillars articulating key themes and Administration priorities. Coming more than two years into the Biden...more

2022 Cyber Watch List: A look at 2021 and What’s to Come in the Year Ahead

Privacy In Focus®- In 2021, cyber gained prominence as a top business risk and national security concern with ransomware attacks wreaking havoc on business operations and critical infrastructure. Companies large and small,...more

TSA Rail Cybersecurity Directives Show Increasing Government Regulation of Critical Infrastructure and the Private Sector

What: The Transportation Security Administration (TSA) has issued two Security Directives aimed at passenger and freight railroad cybersecurity, continuing the government’s move to an increasingly regulatory approach to...more

DHS/CISA Mandates Fixing Security Vulnerabilities, Warning Companies to be Vigilant

The Cybersecurity and Infrastructure Security Agency (CISA) issued a sweeping binding directive to federal agencies to patch hundreds of cybersecurity vulnerabilities that are considered major risks for cyber actors to cause...more

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