On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity theft, in violation of the SEC’s Identity Theft Red Flags Rule, or Regulation S-ID. Regulation S-ID requires registered financial institutions, broker dealers, and investment advisers […]
Board Governance & Cyber Risk Management
UK Information Commissioner’s Office Issues Warning on Ransomware Payments
On July 8, 2022, the UK Information Commissioner’s Office (UK ICO) together with the UK National Cyber Security Centre (NCSC), published a joint letter asking the Law Society of England & Wales to remind its members that they should not advise clients to pay ransomware demands should they fall victim to a cyber-attack. The Law […]
New Cybersecurity Rules In India Impose Strict Reporting Requirements and Steep Penalties
The Indian Computer Emergency Response Team (“CERT-In”) issued Directions on April 28, 2022 “to strengthen the cybersecurity in the country” and that has significant implications for the cybersecurity landscape. Effective June 27, 2022, the Directions, among other requirements, impose a strict 6-hour timeline for notice of a cybersecurity incident and expands the types of cybersecurity […]
Maryland Amends Data Breach and Reasonable Security Requirements
Maryland recently passed House Bill 962, amending Maryland’s Personal Information Protection Act (PIPA) (Md. Code Ann. Comm. Law 14-3504). As summarized below, House Bill 962 amends certain aspects of PIPA relating to breach notification and maintaining reasonable security measures to protect personal information. The bill becomes effective October 1, 2022. Reasonable Security: Beginning October 1, […]
Belgian Supervisory Authority Sanctions News Media Company for Violating Cookie Rules
On May 25th, the Belgian Supervisory Authority (“GBA”) announced that it had imposed a fine of EUR 50,000 on a Belgium-based news media company for using cookies on its websites without complying with applicable cookie law requirements. The GBA decided to sanction the company mainly because although the company had obtained consent from website visitors […]