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Secretary Blinken Announces Next Steps for Creating a Bureau of Cyberspace and Digital Policy at the Department of State

On October 27, 2021, Secretary of State Antony Blinken formally announced plans to modernize and reorient American diplomacy to meet the evolving demands of the 21st century. The State Department, in consultation with...more

Twin DOJ Initiatives Tackle Cybersecurity Fraud and Cryptocurrency Enforcement

Key Points - On October 6, 2021, the DOJ announced two new initiatives: the Civil Cyber-Fraud Initiative and the National Cryptocurrency Enforcement Team. The Civil Cyber-Fraud Initiative will fight rising cyber threats...more

Connecticut Expands Breach Reporting and Creates Cybersecurity Safe Harbor

On October 1, 2021, two Acts overhauling data privacy and cybersecurity in Connecticut took effect—the latest instance of stronger state breach reporting requirements with a safe harbor protection from litigation for...more

Significant Impact on Personal Data Transfers Due to the New Standard Contractual Clauses and Final Guidance on Supplementary...

On September 27, 2021, all new contracts that involve cross-border personal data transfers must incorporate the updated standard contractual clauses (“New SCCs”) for controllers and processors. On June 4, 2021, the European...more

National Artificial Intelligence Advisory Committee Established by Department of Commerce

On September 8, 2021, U.S. Secretary of Commerce Secretary Gina Raimondo announced the establishment of the National Artificial Intelligence (AI) Advisory Committee (NAIAC or the “Committee”). The NAIAC will advise the...more

SEC Cyber Enforcement Actions – Lessons for Private Fund Managers

On August 30, 2021, the Securities and Exchange Commission announced three enforcement actions against registered investment advisers for alleged cybersecurity failures involving cloud-based email systems. All three actions...more

The New PRC Personal Information Protection Law

On August 20, 2021, the 30th session of the Standing Committee of the 13th National People’s Congress (NPC) adopted China’s new PRC Personal Information Protection Law (PIPL), which will take effect on November 1, 2021. The...more

Impact of the New China Data Security Law for International Investors and Businesses

Recent developments in the tech sector in China, including government directives concerning heightened regulatory scrutiny of tech companies listed or looking to list in the US or on exchanges in other overseas jurisdictions,...more

Colorado Privacy Act: What Businesses Need to Know

With the passage of the Colorado Privacy Act (CPA) during its latest legislative session, Colorado has become the third state to enact a comprehensive consumer data privacy law, following California and Virginia. Corporations...more

“No Concrete Harm, No Standing”

Key Points - The U.S. Supreme Court held that all members of a certified class must demonstrate that they suffered a concrete harm—such as physical injury or monetary loss—to have Article III standing to recover damages in...more

New Requirements for UAE Companies Under Updated Targeted Financial Sanctions Guidance

Through updated guidance, the UAE has introduced a significant change to how it administers sanctions regimes—expanding its focus from a limited implementation of multilateral sanctions to more broadly imposing its own...more

Biden Issues Executive Order Redirecting and Clarifying Scrutiny of Chinese Apps

Key Points - On June 9, President Biden signed an executive order (“EO”) revoking a series of Trump-era EOs targeting specific Chinese “connected software applications” (“apps”), including TikTok and WeChat. The EO calls...more

Landmark Supreme Court Decision on Federal Anti-Hacking Law

Key Points - The Supreme Court held that a former police officer did not violate the CFAA by “exceeding” his authorized access to a law enforcement database when he used the database to sell information because he was...more

President Biden Issues Executive Order to Overhaul Cyber and Software Supply Chain Security and Expand Incident Reporting for...

Key Points - On Wednesday, May 12, 2021, President Biden issued EO 14,028, “Improving the Nation’s Cybersecurity.” The EO sets out an ambitious schedule of reviews and rulemakings that portend significant changes in the...more

Second Circuit Weighs in on Article III Standing in Data Breach Lawsuits, Denying Existence of a Circuit Split

While some states have enacted privacy laws granting consumers the right to bring a private right of action in a data breach context, federal courts have struggled to fit data breach injury into traditional Article III...more

Department of Labor’s Cybersecurity Guidance for Benefit Plans Signals Increased Scrutiny

On April 14, 2021, the Department of Labor (DOL) issued its first set of guidance documents related to the cybersecurity of retirement benefit plans covered by the Employee Retirement Income Security Act (ERISA). The...more

New Proposed EU AI Regulation Extends Beyond Europe

On April 21, 2021, the European Commission (Commission) published its draft Regulation on Artificial Intelligence (AI). It follows the strategies outlined in the February 2020 Commission’s White Paper on AI. The draft...more

New York Department of Financial Services Issues Millions of Dollars in Penalties, Signaling Increased Cybersecurity Enforcement

On April 14, 2021, the New York Department of Financial Services (DFS) announced it settled an enforcement action against National Securities Corporation (“National Securities”) related to claims under the Cybersecurity...more

California Supreme Court Increases Privacy Protections for Covered Cellular Communications

The California Supreme Court overturned the California Court of Appeals to hold that a party to a phone call can violate California Penal Code section 632.7 by recording the conversation without the consent of the other...more

[Podcast] 2020 CCPA Litigation Report – Analyzing the First Year of Litigation

In this episode, Akin Gump cybersecurity, privacy and data protection practice co-heads Natasha Kohne and Michelle Reed, and counsel Molly Whitman discuss the firm’s new 2020 CCPA Litigation Annual Report and its...more

UK National AI Strategy Announced Following the AI Roadmap

On March 12, 2021, United Kingdom’s (UK) Digital Secretary Oliver Dowden announced the UK’s forthcoming National Artificial Intelligence (AI) Strategy as he set out his Ten Tech Priorities. The Strategy, which is due to be...more

Virginia Consumer Data Protection Act: What Businesses Need to Know

On March 2, 2021, the Governor of Virginia signed the Virginia Consumer Data Protection Act (CDPA) into law, which goes into effect on January 1, 2023. The law applies only to businesses with large amounts of consumer data...more

FDA Appoints Acting Director of Medical Device Security, Signaling Increased Commitment to Medical Device Cybersecurity

The U.S. Food and Drug Administration (FDA) announced that the newly-created post of Acting Director of Medical Device Security has been filled by Kevin Fu, a University of Michigan associate professor and founder of the...more

Update: Protecting Privilege: Top 10 Checklist for Cybersecurity Forensic Investigation Reports

In ongoing multidistrict litigation concerning Capital One’s 2019 data breach, Capital One succeeded in defeating a motion to compel disclosure of a privileged root cause analysis conducted by PwC. In contrast to an earlier...more

FTC Requires Company to Delete Proprietary Algorithm as Penalty for Alleged Misuse of Data

In an unusual departure from prior settlements, the Federal Trade Commission (FTC) has required a company to delete the facial recognition algorithm that was allegedly developed using improperly obtained user consent....more

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