On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of proposed rulemaking that would require reporting to the FTC of certain cybersecurity events. Revisions to the Safeguards Rule Effective since 2003, […]
Data Security
Department of Justice Announces New Civil Fraud Cybersecurity Enforcement Team
On October 6, 2021, Deputy Attorney General Lisa O. Monaco announced the launch of the Department of Justice’s Civil Cyber-Fraud Initiative. The Department plans to use civil enforcement tools to “pursue…those who are government contractors who receive federal funds, when they fail to follow required cybersecurity standards.” Stating the Department will pursue “very hefty fines,” […]
September 27 Deadline Looming for EU Standard Contractual Clauses
On June 4th, the European Commission issued modernized Standard Contractual Clauses (SCCs) under the EU General Data Protection Regulation (GDPR) for data transfers from controllers or processors in the EU/EEA (or otherwise subject to the EU GDPR) to controllers or processors outside the EU/EEA (and not subject to the EU GDPR). The modernized SCCs will […]
Biden Administration To Issue Cybersecurity “Performance Goals” For Critical Infrastructure
Yesterday, the Biden Administration issued a National Security Memorandum on Improving Cybersecurity for Critical Infrastructure Control Systems (“Memorandum”). A short summary is below. However, the primary take away is that the government will be establishing preliminary cybersecurity performance goals for certain industries no later than September 2021. While we do not yet know what these […]
Securities Class Actions Filed Against Three Chinese Tech Titans After Announcement of Cyber-Related Investigations
In early July, investigations by a Chinese cybersecurity regulatory agency, the Cyberspace Administration of China (“CAC”), into at least three China-based technology companies—DiDi Global Inc. (“DiDi”), Full Truck Alliance Co. Ltd. (“FTA”), and Kanzhun Limited (“Kanzhun”)—were purportedly revealed weeks after each conducted a substantial initial public offering (“IPO”) on a United States stock exchange. These […]