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Banking on Crypto: Regulators Clarify Rules for Digital Asset Safekeeping

Federal banking regulators continue to promote a more "crypto-positive" regulatory environment through recent joint guidance issued to clarify risk management and compliance expectations for banks providing crypto-asset...more

TSA Releases Proposed Rule to Enhance Pipeline and Railroad Cyber Risk Management

The Transportation Security Administration's ("TSA") proposed rule would require owners and operators of certain pipeline, freight railroad, passenger railroad, rail transit, and over-the-road bus ("OTRB") systems to...more

California Proposes CCPA Amendments to Further Protect Children's Privacy

Proposed amendments to the California Consumer Privacy Act would require businesses to obtain opt-in consent prior to collecting, selling, sharing, using, or disclosing a minor's personal information....more

California Privacy: A Deeper Dive Into the New Regulations Expected in 2024

The Background: The California Privacy Protection Agency board ("CPPA" or "Board") is in the process of issuing new regulations as authorized under the California Privacy Rights Act. These three sets of proposed regulations...more

The Department of Defense Proposes the Much-Anticipated CMMC 2.0

On December 26, 2023, the Department of Defense ("DoD") published a proposed rule to implement the Cybersecurity Maturity Model Certification ("CMMC") 2.0, which will establish comprehensive cybersecurity requirements for...more

FTC Seeks to Strengthen Privacy Protections of Children Online

On December 20, 2023, the Federal Trade Commission ("FTC") announced a Notice of Proposed Rulemaking ("NPRM") to revise the Children's Online Privacy Protection Act ("COPPA") Rule to reduce the amount of information...more

New York Governor Proposes Stringent Cybersecurity Regulations for Hospitals

New York is the first state to propose cybersecurity requirements for all hospitals operating in the state to address patient safety and other cybersecurity related issues....more

NYDFS Expands Cybersecurity Regulations: Extortion Payment Reporting, Corporate Governance, and Technical Requirements

A major amendment to the New York State Department of Financial Services' cybersecurity regulations establishes affirmative cybersecurity oversight duties and requires companies to report extortion payments to the agency....more

President Biden Issues Executive Order on "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence"

On October 30, 2023, President Biden signed a first-of-its-kind executive order entitled, "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence" ("AI")....more

The Consumer Financial Protection Bureau Announces Sweeping Rulemaking for Companies That Collect and Furnish Personal Data

On August 15, 2023, the Consumer Financial Protection Bureau ("CFPB") announced it was launching a rulemaking aimed at subjecting any company or entity that collects and sells consumer data to the Fair Credit Reporting Act...more

European Union and United States Reach New Agreement for Data Flow Across the Atlantic

On July 10, 2023, the EU Commission adopted its adequacy decision for the EU-U.S. Data Privacy Framework, concluding that the United States ensures an adequate level of protection for personal data transferred from the...more

Iowa Becomes Sixth State to Enact a Comprehensive Data Privacy Law

On March 28, 2023, Iowa—following California, Colorado, Connecticut, Utah, and Virginia—became the sixth state to adopt a comprehensive consumer data privacy law. On March 28, 2023, Iowa Governor Kim Reynolds signed "An...more

Four Ways to Protect Your Cyber Insurance in Today’s Challenging Market

In Short: The Situation: The cyber insurance market is experiencing a major retrenchment, with insurers seeking to limit their exposure in a variety of ways....more

California Privacy Protection Agency Modifies its Proposed Regulations

In Short - The Situation: The California Privacy Protection Agency ("CPPA" or "Agency") has modified its proposed regulations implementing many key California Privacy Rights Act ("CPRA") requirements....more

New Security Rules for Organizations Supplying Software to the Federal Government

The OMB has issued memorandum M-22-18 with new security requirements (the "Rules") requiring federal agencies to ensure that all third-party software they use complies with secure software development standards and guidance...more

California Attorney General Signals CCPA Enforcement Priorities in $1.2 Million Sephora Settlement

On August 24, 2022, California Attorney General Rob Bonta announced his office's first privacy enforcement action and settlement against a publicly disclosed entity, Sephora, Inc., for violations of the CCPA, including the...more

FTC Issues Record Fine for COPPA Violation

Musical.ly app receives $5.7 million fine for collecting personal information in violation of the Children's Online Privacy Protection Act On February 27, 2019, the Federal Trade Commission ("FTC") issued a record $5.7...more

SEC Announces Yahoo Will Pay $35 Million for Failure to Disclose Data Security Incident

The Situation: The SEC accused Altaba Inc., then known as Yahoo! Inc., of misleading investors by failing to disclose a major data breach orchestrated by Russian hackers. The Result: Altaba has agreed to pay $35 million to...more

Global Privacy & Cybersecurity Update Vol. 13

On December 28, 2016, the New York Department of Financial Services ("DFS") released a revised version of a proposed regulation that would require banks, insurance companies, and other financial services institutions...more

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