On July 30, 2020, the European Council announced sanctions against six individuals and three organizations for their involvement in a series of cyber-attacks that have caused significant damage in the EU and around the world over the last several years. The announcement follows the EU’s adoption last year of Decision (CFSP) 2019/797, which established the […]
Board Governance & Cyber Risk Management
SEC Creates Event and Emerging Risk Examination Team
Following OCIE’s recent and detailed risk alert regarding the threat of ransomware, the SEC today announced that it has created the Event and Emerging Risk Examination Team (EERT) as a part of the Office of Compliance Inspections and Examinations (OCIE). The EERT will engage with registrants regarding emerging threats and current market events, to provide […]
The NYDFS Brings First Enforcement Action under the Cybersecurity Regulation
On Tuesday, July 21, 2020, the New York Department of Financial Services (the “NYDFS”) brought its first enforcement action under its Cybersecurity Regulation (the “Regulation”) against a large title insurer (the “Company”) for failing to protect sensitive personal information. The NYDFS is seeking civil monetary penalties, an order requiring the Company to remedy the alleged […]
EDPB clarifies Brexit obligations for holders of Binding Corporate Rules which have the UK ICO as their lead authority
On July 22, 2020, the European Data Protection Board (‘EDPB’) released an information note on Binding Corporate Rules (‘BCRs’), which provides guidance for groups of undertakings/enterprises which have the UK ICO as their competent supervisory authority (‘BCR Lead SA’) [1]. Binding Corporate Rules are a means of legitimizing transfers of personal data outside of the […]
European Data Protection Board Statement Provides Preliminary Insight into Use of Standard Contractual Clauses Following Schrems II Judgment
On July 17, 2020, the European Data Protection Board (‘EDPB’) published a statement on the outcome of the Schrems II judgment, passed by the Court of Justice of the European Union (‘CJEU’) the day before. The judgment invalidated the EU-U.S. Privacy Shield, and issued a number of clarifications and caveats on the use of Standard […]