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Announcing the Debevoise Tracker for Cybersecurity Incident Disclosure on Form 8-K

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In July, we previewed the new rules adopted by the Securities and Exchange Commission (“SEC”) for Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure. Under these rules, Item 1.05 of Form 8-K requires U.S. public companies to disclose material cybersecurity incidents. We have been tracking Form 8-K filings under the new SEC requirements since the rules went into effect on…

Biden Administration Acts to Limit Access to Sensitive Personal Data by Countries of Concern

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On February 28, 2024, President Biden issued an Executive Order (the “Order”) designed to protect the “sensitive personal data” of Americans from “exploitation” by “countries of concern” or related “covered persons.” Concurrently, the Department of Justice (“DOJ”) released an Advance Notice of Proposed Rulemaking (“Advance Notice”), detailing potential definitions for key terms not defined in the Order, discussing the potential…

European Data Protection Roundup – January 2024

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Key takeaways from January include: Transparency about data processing and retention: In a reminder of the importance of transparency under the GDPR, and the need for companies to make their data subject access request processes easy to navigate, the Dutch data protection authority fined Uber €10 million for, amongst other failings: (i) not specifying to drivers how long it retained…

AI UK Webcast: The Rise in AI Regulation – What to Expect & How to Prepare

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On 18 March 2024, Avi Gesser and Martha Hirst from the Debevoise Data Strategy and Security Group, in conjunction with the AI UK 2024 symposium, presented on the regulatory developments, and associated governance risks, relating to AI use. The presentation included practical guidance that can support businesses’ ability to use AI agilely within a developing regulatory landscape. The proliferation of…

Have You Reviewed Your Form ADV AI Disclosures?

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Registered investment advisers (“RIAs”) have swiftly embraced AI for investment strategy, market research, portfolio management, trading, risk management, and operations.  In response to the exploding use of AI across the securities markets, Chair Gensler of the Securities and Exchange Commission (“SEC”) has declared that he plans to prioritize securities fraud in connection with AI disclosures and warned market participants against…