Our Consumer Protection/FTC and Privacy, Cyber & Data Strategy teams unpack Starwood Hotels’ and Marriott International’s settlements with the Federal Trade Commission and Marriott’s settlement with state attorneys general...more
10/21/2024
/ Civil Monetary Penalty ,
Cybersecurity ,
Data Breach ,
Data Security ,
Federal Trade Commission (FTC) ,
Incident Response Plans ,
Liability ,
Marriott ,
Personal Information ,
Popular ,
Regulatory Authority ,
Risk Assessment ,
Settlement
Threat actors are evolving. Our Privacy, Cyber & Data Strategy Team explains how ransomware gangs have changed their tactics and how companies can respond to the threat while navigating new scrutiny from investors and...more
2/26/2024
/ Corporate Counsel ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Data Security ,
Data Theft ,
NYDFS ,
Popular ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC)
Our Health Care and Privacy, Cyber & Data Strategy Groups delve into the Department of Health and Human Services’ extensive efforts to encourage health care organizations to better protect patients’ privacy through better...more
Our Securities and Privacy, Cyber & Data Strategy teams unpack the Department of Justice’s (DOJ) process for companies seeking to delay Form 8-K disclosures under the Securities and Exchange Commission’s (SEC) cybersecurity...more
After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s...more
Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more
11/13/2023
/ Chief Information Security Officer (CISO) ,
Corporate Liability ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022....more
On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of...more
Entities registered with the U.S. Securities & Exchange Commission (SEC) must maintain certain books and records and can be subject to the SEC’s examination, inspection, and enforcement authority. Responding to SEC requests...more
Ransom demands from cyber-attacks show no signs of slowing down, and the costs—both from ransom payments and repairing the damage—are rising precipitously. Our Privacy, Cyber & Data Strategy Team outlines six ways companies...more
The New York Department of Financial Services (NYDFS) issued new guidance this week intended to assist organizations in thwarting ransomware attacks. The guidance clarifies the NYDFS’ expectation that NYDFS-regulated...more
Following the SolarWinds cyber espionage attack (the “Attack”) and the resulting focus on supply chain risk, the New York Department of Financial Services (NYDFS) has issued a report detailing the impact on and responses by...more
Against the backdrop of the disruptions associated with the Covid-19 pandemic and SolarWinds cyber-espionage campaign, NYDFS has released guidance for insurers that underwrite cyber insurance policies and which contains a...more
2/19/2021
/ Cyber Attacks ,
Cyber Crimes ,
Cyber Insurance ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Information Technology ,
NYDFS ,
Popular ,
Ransomware ,
Risk Management
Cybersecurity incidents—including second wave attacks—are on the rise. Our Privacy, Cyber & Data Strategy Team outlines seven tips for managing a cybersecurity incident—and recovering with strength....more
As the healthcare and financial impacts of COVID-19 continue to evolve with the global pandemic, the use of AI technology and associated risks have received greater attention. On April 8, 2020, the FTC posted an extensive...more
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the...more
4/19/2019
/ Broker-Dealer ,
Cybersecurity ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Policies and Procedures ,
Popular ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC)
On February 28 and March 13, 2019, members of the U.S. Senate and U.S. House of Representatives introduced legislation designed to enhance the transparency of cybersecurity risk oversight at certain SEC reporting companies. ...more
The February 15, 2019 NYDFS compliance certification deadline represents the last annual compliance certification subject to the transition period for covered entities to come into compliance with the cybersecurity...more
On December 28, 2018, the Department of Health and Human Services (HHS) issued new voluntary cybersecurity guidance for the health care industry titled, “Health Industry Cybersecurity Practices: Managing Threats and...more
Michigan enacted the Michigan Data Security Act on December 28, 2018, imposing stringent cybersecurity measures on any person (individual or corporate) licensed by the Michigan Department of Insurance and Financial Services. ...more