Demian Ahn

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As cyberattacks become more sophisticated, cybersecurity remains a top concern for regulators, consumers, business partners, and investors. Weak security can cause substantial harm to a company and lead to litigation, reputational damage, and hefty fines. Against that background, the EU is introducing stricter regulations that require robust cyber resilience, mandate board oversight on cybersecurity strategy, and hold board members personally liable for weak security practices.Continue Reading Cybersecurity: A Critical Element in Your 2025 Business Forecast

On May 16, 2024, the U.S. Securities and Exchange Commission (SEC) announced that it had adopted final amendments to its Regulation S-P (the Rule or Amended Rule), which governs “covered financial institutions’” treatment of consumers’ nonpublic personal information, to ensure that these entities implement incident response programs and notify consumers when their information has been compromised. Brokers, dealers, investment companies, investment advisers, crowdfunding portals, and transfer agents registered with the SEC or another appropriate regulatory agency are all considered covered institutions (CIs) under the Amended Rule.Continue Reading SEC Expands Security and Breach Notification Requirements for Investment Firms

Despite national efforts over the past decades, child sexual abuse material (CSAM) and online child sexual exploitation are still unfortunately prevalent. In 2023, the National Center for Missing and Exploited Children (NCMEC) received over 35.9 million reports of suspected CSAM.[1] This is more than a 20 percent increase over the previous three years. Notably, NCMEC’s 2023 report highlighted concern about the significant increase in reports involving generative artificial intelligence, noting that the Center received 4,700 reports of CSAM or other sexually exploitative content related to these technologies.Continue Reading New Minor Safety Obligations for Online Services: REPORT Act Expands Child Sexual Exploitation Reporting Requirements

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