A recent FTC settlement is the latest example of a regulator imposing very significant costs on a company for artificial intelligence (“AI”) or privacy violations by requiring them to destroy…
On March 15, 2022, President Biden signed the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (the “Act”) into law, requiring critical infrastructure entities to report covered cybersecurity incidents…
On March 9, 2022, the SEC released its newest series of proposed cybersecurity rules, this time for all public companies. Consistent with the proposed rules issued last month for investment…
Since we last wrote about data minimization, there have been several regulatory developments that illustrate the increasing operational and regulatory risks of keeping large volumes of old data. As cyber…
On February 9, 2022, the SEC released its much-anticipated proposed rules relating to cybersecurity risk management, incident reporting, and disclosure for investment advisers and funds. Many of the proposals follow…
On Friday, February 11, 2022, Eric Dinallo and Marshal Bozzo of Debevoise’s Insurance Regulatory practice and Avi Gesser and Anna Gressel of Debevoise’s Data Strategy & Security Group, hosted Part…
The Banking Group of Debevoise & Plimpton LLP has launched the Debevoise Fintech Blog to help financial institutions sift through this complex legal landscape and keep abreast of developments in…
In September 2020, we wrote about the risks of credential stuffing attacks following the New York Attorney General’s (NYAG) settlement with Dunkin’ Donuts. Since then, these attacks have continued, and…
On January 20, 2022, Avi Gesser (Co-Chair of the Debevoise Data Strategy & Security Group), joined a panel discussion with Jon Godfread (North Dakota Insurance Commissioner and Chair of the…
On January 24, 2022, SEC Chair Gary Gensler gave a speech on cybersecurity rulemaking to the Annual Securities Regulation Institute, outlining a number of key points he expects the SEC…