On June 18, 2024, California Attorney General (“AG”) Rob Bonta and Los Angeles City Attorney Hydee Feldstein Soto announced a settlement with a video game developer and publisher regarding allegations that the company violated the California Consumer Privacy Act (the “CCPA”), the federal Children’s Online Privacy Protection Act (“COPPA”) and California’s Unfair Competition Law (the […]
Enforcement
What to Tell Your C-Suite About the EU AI Act
On July 12, 2024, the European Union’s long-awaited Artificial Intelligence Act (AI Act) was finally published. It will enter into force on the twentieth day following its publication; i.e., on August 1, 2024. The AI Act is a landmark legal framework that imposes obligations on both private and public sector actors that develop, import, distribute, […]
SEC Settlement Suggests the Agency’s Attempt to Regulate Cybersecurity Controls
On June 18, 2024, the SEC announced a $2.125 million settlement with R.R. Donnelley & Sons Co. (“RRD”) related to the company’s 2021 ransomware attack (the “Incident”). The settlement, and the SEC’s accompanying cease-and-desist order (the “Order”), portend the agency’s continued and increasing oversight over registrants’ cybersecurity policies and practices. Background RRD is a global […]
DOJ Announces $11.3 Million in Settlements for FCA Violations
On Monday, June 17, 2024, the Department of Justice (DOJ) announced a settlement in which two U.S. based consulting companies agreed to pay a combined total of $11.3 million to resolve allegations that they violated the False Claims Act (FCA) by failing to comply with cybersecurity requirements in government contracts. According to the DOJ, the […]
Data Breach Notification Requirements under the Safeguards Rule Now in Effect
For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial institutions were subject to breach-reporting obligations, these were set by non-GLBA legislation, such as state law, or by relatively narrow incident-reporting rules under Interagency Guidelines overseen by […]