Several recent developments have caused companies to review their whistleblower policies and procedures, especially in the areas of cybersecurity and artificial intelligence (“AI”). First, on October 28, 2021, New York…
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) released an updated advisory (the “Advisory”) on the sanctions risks associated with facilitating ransomware…
Almost everyone working in cybersecurity compliance is aware that each U.S. state has its own set of breach notification requirements. What is less known is that many of these states…
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated advisory (the “Advisory”) on sanctions risks associated with payments to threat…
As part of our ongoing series on enforcement actions by the Securities and Exchange Commission (“SEC”) in data- and cybersecurity-related matters (here, here, and here), we have been closely tracking…
Key takeaways from developments this August include: Indications of what the UK’s post-Brexit data transfer arrangements might look like – companies transferring data from the UK will want to follow…
On August 30, 2021, the SEC filed settled enforcement actions against three groups of broker-dealers and investment advisers for failing to protect confidential customer information in violation of Rule 30(a)…
The U.S. Securities and Exchange Commission this week took the rare step of penalizing a company for its allegedly poor disclosure of a cyber incident. The SEC announced a $1…
Earlier this year, we wrote about the SEC’s cybersecurity priorities. Since then, the SEC announced a settlement with First American Title Insurance and Services (“First American”) for violating Rule 13a-15(a)…
Our three previous articles in this series on the future of AI regulation have discussed the RFI on AI issued by U.S. banking regulators, the draft EU AI regulation, and…