On December 19, 2023, the Justice Department (“DOJ”) announced a disruption campaign against the Blackcat ransomware group. In the same press release, they also stated that the Federal Bureau of Investigation (“FBI”) had developed a decryption tool to combat ALPHV/Blackcat’s ransomware variant. Over the last couple of years, Blackcat’s ransomware has risen in popularity and […]
Board Governance & Cyber Risk Management
EU’s Highest Court Issues Major AI Decision With Wide-Reaching Impact
On 7 December 2023, the Court of Justice of the European Union (CJEU) issued an important decision on how the GDPR governs AI-assisted decisions. The case arose in the financial services context, with the court holding that the GDPR’s AI rules apply when banks use credit scores to make consumer credit decisions. But, the decision […]
NYDFS Releases Consent Order in First Enforcement Action Brought Under the Cybersecurity Regulations
After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s Cybersecurity Regulation (23 NYCRR Part 500) (the “Regulation”), specifically, its failure to protect non-public information (“NPI”). NYDFS originally brought the enforcement action in […]
CPPA Publishes Revised Cybersecurity Audit Regulations in Advance of Board Meeting
On December 8, 2023, the California Privacy Protection Agency (CPPA) will hold a board meeting seeking public comment on various privacy regulations. The meeting, which will take place on Zoom, will cover several topics listed in its published agenda. The New CPRA Rules Subcommittee will provide an update and present on the Draft Regulations on […]
Colorado AG Publishes Shortlist of Universal Opt-Out Mechanisms
On November 21, 2023, the Colorado Attorney General (the “AG”) published a shortlist of potential universal opt-out mechanisms (“UOOMs”) that the AG is considering recognizing as binding under the Colorado Privacy Act (the “CPA”). Beginning on July 1, 2024, the CPA will require covered controllers to comply with Colorado consumers’ requests to opt out of […]