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Data Protection Disclosure Requirements Enforcement Actions

Frost Brown Todd

Growing Cybersecurity Risks in the Municipal Bond Market

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In November 2024, the Township of White Lake, Michigan, fell victim to a cyberattack resulting in the wiring of approximately $29 million to the unauthorized account of the culprit. Before White Lake imminently closed on its...more

Verrill

Minnesota’s Consumer Data Privacy Act: An Overview

Verrill on

Twenty-nine years after Prince warned us about the dangers of the Internet, his home state has taken action to protect consumers who use it. On July 31, 2025, Minnesota joined the roughly twenty states that have adopted...more

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...more

Sheppard Mullin Richter & Hampton LLP

Oregon’s Privacy Law: Six Month Update, With Six Months to End of Cure Period

Oregon’s Attorney General released a new report this month, summarizing the outcomes since Oregon’s “comprehensive” privacy law took effect six months ago. A six-month report isn’t new: Connecticut released a six month report...more

Vinson & Elkins LLP

Watch What You Say: SEC Enforcement Scrutinizes Cybersecurity Incident Disclosures

Vinson & Elkins LLP on

On January 13, 2025, the Securities and Exchange Commission (“SEC”) filed a settled enforcement action against Ashford Inc. (“Ashford” or “the Company”), a company that provides products and services to the real estate and...more

Troutman Pepper Locke

SEC Issues Additional Guidance Regarding Cybersecurity Incident Disclosure

Troutman Pepper Locke on

On June 24, the staff of the U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division of Corporation Finance) released five new Compliance & Disclosure Interpretations (C&DIs) relating to the...more

Holland & Knight LLP

SEC Cyber Enforcement Update: Which Way Are the SolarWinds Blowing?

Holland & Knight LLP on

The SEC has been aggressively pursuing cybersecurity investigations and enforcement actions against public companies and foreign private issuers. In these actions, the SEC often alleges one of two theories: 1) that the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

A&O Shearman

SEC Brings Groundbreaking Claims Against Company For Fraud Relating To Data Breach

A&O Shearman on

On October 30, 2023, the Securities and Exchange Commission filed claims against a software company (the “Company”) and its Chief Information Security Officer for alleged fraud and internal control failures relating to known...more

McDermott Will & Schulte

For the General Counsel’s Desk: Managing Enforcement Risks Involving Cookies, Pixels, and Other Tracking Technologies

Data governance is a mission-critical issue for every company and institution in the United States. GCs face a host of pressing cybersecurity concerns. Triaging them requires time, attention, and a well-rounded strategy...more

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

Jenner & Block on

Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

Mayer Brown Free Writings + Perspectives

Blackbaud Inc. to Pay $3 Million to SEC for Alleged Misleading Disclosures in 2020 Ransomware Attack

On March 9, 2023, the Securities and Exchange Commission (“SEC”) announced that Blackbaud Inc. (“Blackbaud”) agreed to pay $3 million to settle charges for alleged misleading disclosures about its 2020 ransomware attack and...more

Davis Wright Tremaine LLP

SEC Settles Ransomware Disclosure Charges for $3 Million

The U.S. Securities and Exchange Commission ("SEC" or the "Commission") has ordered Blackbaud, Inc. ("Blackbaud") to pay $3 million to resolve claims that it made materially misleading statements about a 2020 ransomware...more

Perkins Coie

Answers to Common Questions Regarding New CIRCIA

Perkins Coie on

President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The enactment of CIRCIA follows attacks on critical infrastructure, such as the May 2021...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

Holland & Knight LLP on

Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

Brownstein Hyatt Farber Schreck

When Should a Public Company Disclose a PCI Breach?

As companies collect growing amounts of data about their customers and other consumers, sophisticated adversaries, recognizing the value of this information, have increased their efforts to pilfer it. For publicly traded...more

Brooks Pierce

Virginia Becomes the Second State—and the First on the Eastern Seaboard—to Adopt a Comprehensive Data Protection Law

Brooks Pierce on

In March of 2021, Virginia became the second state to adopt a comprehensive data protection law. The Virginia Consumer Data Protection Act (VCDPA), which goes into effect on Jan. 1, 2023, borrows many concepts from the...more

Goodwin

CCPA 2.0 Passes: The California Privacy Rights Act To Become Law

Goodwin on

On November 3, 2020, California voters convincingly approved the California Privacy Rights Act (“CPRA”) ballot initiative. The CPRA builds upon and amends the California Consumer Protection Act (“CCPA”), aligning it more with...more

Akin Gump Strauss Hauer & Feld LLP

In Principle: 10 Things Authorised Firms Need to Know for 2020

Welcome to the 2020 edition of In Principle. With the United Kingdom (UK) leaving the European Union (EU) on31 January 2020, and moving into a transition period which will last until 31 December 2020, Brexit of courselooms...more

Foley Hoag LLP - Security, Privacy and the...

Move over, CCPA? New York Considers Sweeping Data Privacy Law

New York’s state legislature is considering a new data privacy law that would set the standard for data privacy in the U.S. The New York Privacy Act (the “NYPA” or the “Act”), which is currently being considered by the state...more

Orrick, Herrington & Sutcliffe LLP

Google To Pay $57 Million For GDPR Violations

On January 21, 2019, the French data protection supervisory authority (“CNIL”) fined Google €50 million (approximately $57 million) for violating the European General Data Protection Regulation (“GDPR”). ...more

McDermott Will & Schulte

2018 Digital Health Data Developments – Navigating Change in 2019

Data privacy and security legislation and enforcement saw significant activity in 2018 and early 2019. McDermott’s 2018 Digital Health Year in Review: Focus on Data report – the first in a four-part series – highlights...more

Foley Hoag LLP - Security, Privacy and the...

GDPR Alert: Google Gets Biggest Fine Ever Issued by a European Data Protection Authority

On 21 January 2019, the French Data Protection Authority (the “French DPA”) fined Google LLC 50 million euros for breach of the GDPR. As we reported on this blog, just after GDPR became applicable, noyb.eu (None of Your...more

Fenwick & West LLP

Deregulation is the New Buzzword in Washington — Except in the Tech Industry

Fenwick & West LLP on

The past year has been a volatile one, from trade wars to the government shutdown to a stock market dive. One constant that U.S. businesses have become accustomed to, however, is deregulation across a wide variety of...more

Akin Gump Strauss Hauer & Feld LLP

Top 10 Topics for Directors in 2019

1. Corporate Culture - The corporate culture of a company starts at the top, with the board of directors, and directors should be attuned not only to the company’s business, but also to its people and values across the...more

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