Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires […]
DOJ Releases Guidance On Gathering Threat Intel From The Dark Web
The Cybersecurity Unit (“CsU”) of the Computer Crime and Intellectual Property Section of the Criminal Division of the United States Department of Justice (“CCIPS”) has released its guidance on “Legal Considerations when Gathering Online Cyber Threat Intelligence and Purchasing Data from Illicit Sources” (“Guidance”). The CsU prepared the Guidance—with input from the FBI, the U.S. […]
High Profile Settlements, Strengthened Data Security Orders, and COPPA: The FTC’s 2019 Privacy and Data Security Update
Each year the Federal Trade Commission (the “FTC” or “Commission”) publishes a report on its activities with respect to consumer privacy and data security during the prior year. On February 25, 2020, the Commission released its 2019 Privacy and Data Security Update. The update contains a summary of the FTC’s enforcement, advocacy, and rulemaking actions […]
DOJ Indicts Chinese Military Personnel for Involvement in 2017 Equifax Breach
On February 10, 2020, the U.S. Department of Justice announced charges against four members of China’s People’s Liberation Army (“PLA”) for their alleged involvement in the 2017 Equifax hack that resulted in the theft of the personal information of 145 million Americans. In the nine-count indictment, the four individuals, Wu Zhiyong, Wang Qian, Xu Ke, […]
SEC Releases Detailed Set of “Cybersecurity and Resiliency Observations”
On January 28, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a detailed set of observations culled from thousands of examinations of registered investment advisers, broker-dealers, clearing agencies, national exchanges, and other SEC registrants (“Observations”). These Observations represent the most detailed compilation of strategies and tools that OCIE has observed to promote […]