The SEC has settled an enforcement action against a large title insurer in connection with public statements and disclosures made by the company in May 2019 relating to a data security incident. The underlying data security incident was the subject of the first set of charges brought by the New York Division of Financial Services […]
Enforcement
New York and Illinois Regulators Recommend Third Party Cybersecurity Review For Specific Vulnerabilities
This month, the Illinois Department of Insurance issued guidance to insurers recommending assessments in response to a Microsoft Exchange vulnerability, detailed in the guidance. In the Bulletin dated May 5, the Department encourages regulated entities to “assess the risk to their systems and consumers and take steps necessary to address vulnerabilities and customer impact.” The […]
Swire Report Addresses EU Data Localization Comments, Portuguese Order Restricting U.S. Data Flow
In November, the European Data Protection Board (EDPB) issued draft guidance regarding transfers of personal data from the European Union. That guidance has prompted nearly 200 comments from companies, trade groups, and interested observers. Senior Counsel Peter Swire, along with co-author DeBrae Kennedy-Mayo, has now published a report reviewing these comments through the Cross Border […]
Russia Sanctioned For Role In SolarWinds Supply Chain Attack
On April 15, 2021, the Biden Administration took a significant step in announcing sanctions against the Russian Government and private Russian entities for multiple internationally-destabilizing activities, including the Russian Foreign Intelligence Service’s (SVR) supply chain attack of the SolarWinds Orion platform and other technology infrastructures. In addition to the sanctions, the Administration also provided practical […]
NYDFS Announces Cybersecurity Settlement, Addresses Multi-Factor Authentication Rules
On April 14, 2021, the New York Department of Financial Services (“NYDFS”) announced a settlement with National Securities Corporation (“National Securities”), a licensed insurer, in connection with claims under the NYDFS Cybersecurity Regulation (23 NYCRR Part 500). The consent order requires payment of a $3M penalty and mandatory remediation in response to alleged failures to […]