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Welcome to your monthly legal insights on the trends impacting the Retail, Hospitality, and Food & Beverage Industries. Alcohol Law - New Colorado Law Limits Grocery Stores’ Ability to Sell Hard Alcohol - Michael...more
On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more
On April 8, the OCC announced it had notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident involved unauthorized access to emails and their...more
The latest edition of the Consumer Finance State Roundup highlights recently enacted measures of potential interest from two states: California: Effective January 1, California Assembly Bill 3108 addresses mortgage fraud. ...more
Recent statements by South Africa’s Information Regulator (“IR”) indicate an impending crackdown on data privacy compliance, specifically within the banking and insurance sectors. The IR has announced its intention to enforce...more
In May, Santander Bank faced a significant cybersecurity breach that affected millions of its customers and employees worldwide. The hacking group ShinyHunters claimed responsibility for the attack, which also targeted...more
On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more
Against the backdrop of the National Cybersecurity Strategy’s stated goal of harmonizing federal cyber incident reporting requirements, new requirements still continue to emerge. Among the latest is a Federal Trade Commission...more
Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s dedicated Privacy and Cybersecurity team. Updata provides you with a compilation of privacy and cybersecurity regulatory and...more
On October 27, the FTC approved an amendment to the Safeguards Rule to require nonbanks to report data breaches. Under the amended rule, financial institutions, including mortgage brokers, motor vehicle dealers, and payday...more
On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...more
On June 30, 2023, City National Bank of Florida (“CNBF”) filed a notice of data breach with the Attorney General of Maine, explaining that 36,306 of the bank’s customers were affected by a data breach involving software...more
Financial institutions are in a tough spot- caught between the “bad guys” (state-sponsored cyberattacks and cyber criminals) and “good guys” (ever more aggressive regulators)- what’s a bank to do??? Tune in to find out!...more
The Massachusetts State Police Commonwealth Fusion Center (CFC) believes that cyber actors may use the current bank failures for future phishing and business email compromise (BEC) attacks. Cyber actors often use current...more
While ransomware attacks usually grab the headlines, business email compromise (BEC) attacks continue to cause massive financial losses for businesses. The FBI’s Internet Crime Complaint Center (IC3), reported BEC losses in...more
Welcome to the first edition of the Payments Docket, our roundup of key litigation involving the payment industry. This edition features a stolen cell phone number used to buy cryptocurrency, a pair of class actions accusing...more
Given the omnipresent concern about cyber attacks targeting the banking industry, the FDIC, OCC and Federal Reserve recently published a new joint final rule establishing enhanced security incident notification requirements...more
Banking organizations must notify the appropriate agency within 36 hours of certain computer-security incidents; and banking service providers must notify affected banking organizations as soon as possible in the event of an...more
As the federal government continues its whole-of-government response to cyber incidents, federal banking regulators took action to impose a new notice requirement on federally regulated banks. In November, the Federal Deposit...more
On November 23, 2021, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Federal Reserve Board (the “Prudential Regulators”) exercised their collective...more
Federal banking regulators issued a final rule that impacts how banks and other regulated entities report certain data incidents. Those subject to these new reporting requirements include U.S. banks and bank service...more
On November 18, 2021, three US agencies – the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) – issued a joint rule concerning...more
On November 18, 2021, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) issued a joint final rule (the...more
The three federal banking agencies (i.e., the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency—collectively, the Agencies) published a final rule (the Rule)...more
Introduction - On November 18, federal banking agencies issued the long-awaited final rule, establishing data security incident response notification requirements for “banking organizations” and “bank service providers”...more