Compliance Tip of the Day: Bringing Predictive Analytics into Your Compliance Regime
Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 2 - Risk Assessment
FCPA Compliance Report: Fraud Risk Management - Insights and Experiences with Peter Schablik
#Risk New York Speaker Series – Inside Behavioral Insights: Tom Hardin on Compliance at #RiskNYC
Compliance Tip of the Day: COSO Framework
#Risk New York Speaker Series: Exploring AI Risks in Compliance with Gwen Hassan
Healthcare Enterprise Risk Management
Managing Sanctions Compliance
Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
Episode 364 -- Five Strategies to Mitigate a New Risk Environment
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Compliance and AI: Ali Khan on Implementing AI Risk Management Systems
Compliance Tip of the Day: Superforecasting
Compliance Tip of the Day: The Last Mile
The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more
Publications & Advisories - November 2024 – Kathleen Benway, Jennifer Everett, Alysa Austin, and Kristen Bartolotta published “Federal Trade Commission’s Updated Health Breach Notification Rule Is Now in Effect” in Employee...more
On October 2, 2024, New York adopted new regulations requiring general hospitals to implement heightened cybersecurity safeguards. General hospitals, as defined in Article 28 of the NY Public Health Law, generally must begin...more
The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently settled two ransomware cases with covered entities. These cases signal the government's growing concern with health care...more
The cyber breach at Change Healthcare in 2024 stands out as one of the most significant cyber-attacks in recent memory. Its repercussions extend far beyond immediate industry disruptions, resonating deeply in regulatory...more
The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) has, as part of its mandate, the responsibility to enforce the Health Insurance Portability and Accountability Act (HIPAA) Security Rule....more
The consequences of a cyberattack can be catastrophic, as we saw in the previous blog of this series. Cybersecurity is a business-wide responsibility that demands a proactive strategy extending far beyond technical solutions...more
The Department of Health and Human Services (HHS), Office for Civil Rights (OCR) recently announced a settlement under the Health Insurance Portability and Accountability Act (HIPAA) with Green Ridge Behavioral Health, LLC...more
New York has released proposed cybersecurity regulations for hospitals. The regulations, which were published in The State Register on Dec. 6 and will undergo a 60-day public comment period ending on Feb. 5, are designed to...more
Report on Patient Privacy 23, no. 10 (October, 2023) Kaiser Foundation Health Plan Inc. and Kaiser Foundation Hospitals will pay California $49 million to resolve allegations that they unlawfully disposed of hazardous waste,...more
Typically, we beat the drum of the need to prepare for a data incident—anything from a full-blown ransomware attack to an employee accidently sharing data with the wrong person—by having your Incident Response Plan developed...more
In recent years, especially through 2019 and 2020, the cyber insurance market in the U.S. has seen significant growth. Middle-market companies have been actively requesting cyber insurance policies with low rates and broad...more
Crises and uncertainty are inevitable forces in modern business, particularly in cyber and digital. General counsels and legal risk executives are well suited to lead preparedness and resiliency for future crises, uniting key...more
Organizations attacked with ransomware have a bevy of decisions to make, very quickly! One of those decisions is whether to pay the ransom. Earlier this year, I had the honor of contributing to a two-part series, entitled...more
Healthcare companies continue to face increased risks of ransomware attacks on their operations. According to the recently released BD Cybersecurity Annual Report for 2021, such attacks are also increasingly sophisticated....more
Report on Patient Privacy 22, no. 1 (January, 2022) - As the COVID-19 pandemic enters its third year, real “security fatigue” with pandemic-related issues will combine with cybercriminals’ increasingly sophisticated...more
Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more
Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more
On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...more
A ransomware attack is a major threat affecting all sectors of business, including healthcare. Organizations typically follow state and federal privacy laws as part of their ransomware prevention and response measures....more
Labor Day weekend is upon us. Unfortunately, history has shown that, rather than resting, hackers and other threat actors take advantage of holidays to attack closed or understaffed businesses when they least expect it. To...more
A ransomware attack is no company’s idea of a good time, but I do sense one positive development emerging from the epidemic of attacks we’ve witnessed this year: Boards and senior management agree that they must move beyond a...more
On May 27, 2021, against the backdrop of the Colonial Pipeline cybersecurity incident, the Department of Homeland Security’s Transportation Security Administration (“TSA”) announced Security Directive Pipeline-2021-01...more
On February 4, 2021, New York’s Department of Financial Services (DFS) issued Insurance Circular Letter No. 2, which builds on the robust cybersecurity regulation provided in its 2017 Cybersecurity Regulation (23 NYCRR 500)....more
Both the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury have issued advisories recently regarding regulatory considerations financial...more