Demian Ahn

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On February 28, 2024, President Biden signed Executive Order 14117 (the Order) aimed at protecting Americans’ sensitive personal data and U.S. Government-related data from exploitation by “countries of concern.” This move constitutes a transformative overhaul in the U.S. approach to data regulation and creates the foundation for a comprehensive regulatory structure governing U.S. data.Continue Reading New Executive Order Restricts Certain Cross-Border Transactions Involving Sensitive Personal Data of U.S. Citizens

In 2024, businesses will continue to face an evolving landscape of cyber threats, along with an increasingly complex regulatory environment. With heightened scrutiny from regulators, consumers, and investors, the need to bolster security measures and improve incident response capabilities has become even more important. Here’s our top 10 list of what to watch for from cybersecurity regulators in 2024:Continue Reading Cybersecurity: What to Watch for in 2024

On October 27, 2023, the Federal Trade Commission (FTC) announced it is amending the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA) to include a requirement for non-bank financial institutions to report certain data breaches and other security events to the agency.Continue Reading FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches

Reflective of the Government’s increasing focus on cybersecurity, on October 3, 2023, the Federal Acquisition Regulation Council (FAR Council) released two new proposed rules that will have major impacts on federal contractors. These rules implement the May 2021 Executive Order on Improving the Nation’s Cybersecurity.1 One rule applies to any federal contractor that uses information and communications technology (ICT) systems in the performance of a federal contract, sets forth cybersecurity incident reporting requirements, and imposes a software bill of materials (SBOM) requirement. The other rule, which applies only to those federal contractors that provide or maintain a Federal Information System (FIS), is intended to standardize cybersecurity requirements for unclassified FISs.Continue Reading New Proposed Rules Published for Cyber Incident Reporting and Cybersecurity Requirements Will Have Major Impacts on Federal Contractors

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) announced that it adopted final rules requiring disclosure by public companies of material cybersecurity incidents in a Current Report on Form 8-K, and of material information regarding their cybersecurity risk management, strategy, and governance in an Annual Report on Form 10-K. Foreign private issuers will be required to make comparable disclosures on Forms 6-K and 20-F. Set forth below is a brief summary of the final rules; a more detailed client alert will follow.Continue Reading SEC Adopts Cybersecurity Disclosure Rules

Earlier this month, the U.S. Securities and Exchange Commission’s (SEC) 2023 Spring Unified Agenda of Regulatory and Deregulatory Actions was released. The agenda identifies the rules that the agency expects to consider in the next 12 months and includes an anticipated action date for finalizing rules for cybersecurity disclosure by public companies by October 2023. This alert provides guidance on what companies should be doing to prepare now.Continue Reading SEC Adjusts Anticipated Action Date for Publication of Final Rules for Cybersecurity Reporting and Enhanced Standardized Disclosure

On March 2, 2023, the White House released its National Cybersecurity Strategy (the Strategy). The Strategy sets out ambitious goals for the federal government to hold countries accountable for irresponsible behavior in cyberspace and to…

Continue Reading White House Releases National Cybersecurity Strategy: Key Takeaways for the Private Sector