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Recent months have seen a spate of high-profile cyber incidents that have affected UK companies and disrupted supply chains, keeping cybersecurity on the front pages and at the top of UK companies’ agendas. In response to the...more
On Feb. 20, the U.S. Securities and Exchange Commission announced the creation of the Cyber and Emerging Technologies Unit, which will replace the Enforcement Division’s previous Crypto Assets and Cyber Unit. Originally...more
Adopted in July 2023, the US Securities and Exchange Commission (SEC)’s cybersecurity disclosure rules require public companies to report material cybersecurity incidents on Form 8-K and to annually report on their...more
Securities and Exchange Commission (SEC) Chairman Paul S. Atkins recently directed SEC staff to conduct a review of the Consolidated Audit Trail (CAT), focusing on the escalating costs, reporting requirements, and...more
Since its announcement during the King’s Speech on 17 July 2024, there has been much anticipation over the contents of the Cyber Security and Resilience Bill (“CS&R Bill“) and in particular the extent to which it will bring...more
On 1 April 2025, the UK Department for Science, Innovation and Technology issued a policy statement setting out its key proposals for the new Cyber Security and Resilience Bill. The Bill is intended to respond to an...more
The UK government published on April 1 a policy statement setting out its proposals for the much-anticipated Cyber Security and Resilience Bill (the Bill). The proposals include bringing data centers and managed service...more
Lawmakers expressed bipartisan support for significantly amending or eliminating some cybersecurity incident notification requirements during a recent hearing of the U.S. House Committee on Homeland Security's Subcommittee on...more
1. Bank regulation - 1.1 PRUDENTIAL REGULATION - a) General - (i) International - FSB: Plenary December 2024 - Status: Final - The FSB has set out the outcomes of its Plenary that met on 3 and 4 December. Points of...more
On June 24, the Securities and Exchange Commission (SEC) released five additional Compliance and Disclosure Interpretations for Item 1.05 of Form 8-K (Material Cybersecurity Incidents). These interpretations provide...more
The Cybersecurity and Infrastructure Security Agency (“CISA”) recently released its new Proposed Rule pursuant to the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which was published in the...more
On December 21, 2023, the Department of Defense (DoD) issued a memorandum (Memo) providing guidance and clarification on the security and cyber incident management requirements applicable for the use of external Cloud Service...more
Corporate legal departments are scrambling to stay ahead of the latest developments around cyber incident disclosure rules and regulations. In hopes of reducing panic and distress, a pair of legal experts are issuing a...more
On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more
On October 30, 2023, the Biden administration issued a sweeping Executive Order on the Safe, Secure and Trustworthy Development and Use of Artificial Intelligence (the “Executive Order”), which ambitiously directs the...more
On October 30, 2023, President Biden signed the Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence (the “Federal AI Executive Order”), a long-awaited executive order that builds upon the Biden...more
On July 26, 2023, the SEC adopted new cybersecurity rules, which have two top-line impacts. First, registrants must disclose material cybersecurity incidents promptly on Form 8-K. Second, registrants must disclose new...more
The Securities and Exchange Commission (“SEC”) voted on July 26, 2023 to adopt new cybersecurity rules, which are aimed at helping investors better understand the cybersecurity risks associated with public companies by...more
In May 2021, Colonial Pipeline, a privately held oil pipeline responsible for nearly half of the oil supply for the U.S. East Coast, was crippled by a DarkSide ransomware attack. DarkSide is widely believed to be a...more
President Joe Biden signed the Strengthening American Cybersecurity Act into law on March 15. Among other requirements, companies that are “covered entities” must report data breaches promptly to federal regulators. For...more
On March 15, 2022, President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (the "Act"), creating new requirements for organizations operating in critical infrastructure sectors to...more
On March 9, 2022, the US Securities and Exchange Commission (SEC) voted 3-1 to propose new rules and amendments under the Securities Exchange Act of 1934 that would constitute the SEC’s first attempt to adopt specific rules...more
Increased premarket submission and post-market reporting requirements potentially on the horizon for high-tech devices. The Food and Drug Administration’s (“FDA’s”) budget proposal for FY2021 telegraphs FDA’s plan to seek new...more