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Kim Peretti

Key Takeaways from OFAC’s Updated Ransomware Advisory

September 23, 2021 By Kim Peretti and Lance Taubin

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” While this advisory explicitly supersedes OFAC’s previous ransomware advisory from October 2020, it does not fundamentally alter OFAC’s approach towards ransom payments.  Like the prior guidance, OFAC’s […]

Filed Under: Data Breach, Ransomware, Security Breach

People’s Republic of China Passes the Data Security Law: A Summary of What We Know

July 7, 2021 By Kim Peretti and Lance Taubin

  On June 10, 2021, almost exactly three years after the passing of its Cybersecurity Law (CSL), the National People’s Congress of China passed a new Data Security Law (DSL) (click here for an unofficial English translation of the DSL), which goes into effect September 1, 2021. Where the CSL is primarily focused on cybersecurity […]

Filed Under: China, Data Security

NYDFS Issues Guidance on Cybersecurity Controls to Combat Ransomware and Clarifies Reporting Obligations

July 3, 2021 By Lance Taubin, Kate Hanniford and Kim Peretti

The New York Department of Financial Services (NYDFS) issued new guidance this week intended to assist organizations in thwarting ransomware attacks. The guidance clarifies the NYDFS’ expectation that NYDFS-regulated companies should “implement these controls whenever possible” and report any successful deployment of ransomware or unauthorized access to privilege accounts to the NYDFS under its established […]

Filed Under: Cybersecurity, NYDFS Tagged With: Ransomware

U.S. Takes Unprecedented Action to Disrupt State-Sponsored Exploitation of Microsoft Exchange Zero-Day Vulnerabilities

April 19, 2021 By Kim Peretti and Kate Hanniford

On April 13, 2021, a federal district court granted a motion to partially unseal an FBI application and search warrant following the successful conclusion of an FBI operation to eradicate malicious web shells placed on U.S.-based computers by Chinese state-sponsored actors.  The FBI’s use of credentialed, remote access techniques to access, copy, and remove malware […]

Filed Under: China, Digital Crimes, National Security, Uncategorized

Financial Regulatory Agencies Announce Proposed Rule Requiring Notice of Computer Security Incidents

January 12, 2021 By Kim Peretti

On December 18, 2020, federal financial regulatory agencies jointly announced a proposed rule that would impose new and expanded reporting requirements on supervised banking organizations that experience a “computer-security incident,” requiring notice within 36 hours of any computer-security incident that rises to the level of a “notification incident.” In a significant departure from current reporting […]

Filed Under: Cybercrime, Cybersecurity, Data Security, Enforcement, NYDFS Tagged With: Bank Secrecy Act (BSA), Board of Governors of the Federal Reserve System, Computer-Security Incident, FDIC, Gramm-Leach-Bliley Act (GLBA), Notice of Proposed Rulemaking, Office of the Comptroller of the Currency (OCC), Suspicious Activity Report (SAR)

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