On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) published a notice of proposed rulemaking (NPRM) implementing the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA). For...more
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)
Recently, there has been a surge in alerts and warnings concerning cyberattacks by People’s Republic of China (PRC) state-sponsored threat actors on U.S. critical infrastructure. On February 7, 2024, the Federal Bureau of...more
On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information...more
On January 24, 2024, the U.K.’s National Cyber Security Centre (NCSC) released a new report, The near-term impact of AI on the cyber threat, detailing how Artificial Intelligence (AI) will impact the effectiveness of cyber...more
On January 12, 2024, the New York State Department of Financial Services (“NYDFS”) released a new Industry Letter on the use of self-service password reset (“SSPR”) services, which enable users to reset their own password...more
On January 5, 2024, the New York Attorney General’s Office (“NY AG”) announced a settlement with Refuah Health Center, Inc. (“Refuah”) based on the company’s alleged failures to appropriately safeguard its patients’...more
On December 19, 2023, the Justice Department (“DOJ”) announced a disruption campaign against the Blackcat ransomware group. In the same press release, they also stated that the Federal Bureau of Investigation (“FBI”) had...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 decade and a half under the current data breach notification rules for telecommunications carriers and telecommunications relay services (TRS) providers, the FCC recently unveiled plans to update and expand them....more
Just a month before the Security and Exchange Commission’s (“SEC’s”) Material Cybersecurity Incidents Rule is set to take effect, a ransomware group has apparently taken compliance with reporting requirements into its own...more
With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...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
Our Privacy, Cyber & Data Strategy Group considers the nationwide repercussions of Colorado’s new regulation of insurers’ use of artificial intelligence models to prevent race-based discrimination....more
The Federal Bureau of Investigation (FBI) issued a Private Industry Notification on September 27, 2023, highlighting two concerning ransomware trends and providing companies with guidance on mitigating potential threat actor...more
At the end of September 2023, the Cyberspace Administration of China (CAC) released draft regulations (see the unofficial English translation) regulating the cross-border flow of personal information and important data out of...more
On October 4, 2023, the National Security Agency (NSA) and Cybersecurity and Infrastructure Security Agency (CISA) published Identity and Access Management: Developer and Vendor Challenges, an advisory document developed by...more
On September 27, 2023, The U.S. National Security Agency (NSA), the U.S. Federal Bureau of Investigation (FBI), the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the Japanese National Police Agency (NPA), and...more
New York Attorney General Letitia James recently announced two agreements related to data breaches with entities that operate in the education industry. In both instances the entities paid the ransom and received evidence of...more
In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”)....more
Publications and Advisories - July 31, 2023 – Dave Brown, Kate Hanniford, Kim Peretti, Julia Mediamolle, Cara Peterman, Sierra Shear, Kristen Bartolotta, and Kezia Osunsade published “Securities Law, Securities Litigation,...more
8/10/2023
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
Civil Investigation Demand ,
COPPA ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Hackers ,
International Data Transfers ,
Online Safety for Children ,
Popular ,
Ransomware ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Standard Contractual Clauses ,
Telehealth
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s final changes to its cybersecurity reporting rules for public companies...more
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more