On October 13, 2020, state financial regulators in partnership with the Bankers Electronic Crimes Taskforce and the U.S. Secret Service, released the Ransomware Self-Assessment Tool (R-SAT) to help financial institutions mitigate the risks of ransomware. The R-SAT is a detailed questionnaire designed to evaluate the effectiveness of an institution’s general security controls as well as […]
Enforcement
New Privacy Browser Extension Released under CCPA Global Do Not Sell Rules
On October 7, 2020, an organization named Global Privacy Control (“GPC”) issued a press release announcing an initiative to make a new “global privacy control” available to consumers as contemplated by the CCPA Regulations. As analyzed in prior advisories, the CCPA Regulations appear to revive the possibility for Do Not Track technology, albeit in the […]
FinCEN Alerts Financial Institutions on Role in Facilitating Ransomware Attacks
With an increase in the frequency, sophistication, and cost of ransomware attacks, the Financial Crimes Enforcement Network (FinCEN) issued an advisory on October 1, 2020 alerting financial institutions to ransomware trends and typologies, and related financial red flags, that may result in a regulatory obligation to report and share information related to ransomware attacks. Based […]
OFAC Ransomware Advisory Warns Companies of Potential Civil Liability
Yesterday, October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued its “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The advisory begins with the observation that “ransomware attacks have become more focused, sophisticated, costly, and numerous,” citing certain FBI statistics, before making clear what was already well […]
DOJ Charges Seven Individuals in Connection with Global Hacking Campaigns Against More Than 100 Companies
On September 16, 2020, the U.S. Department of Justice (DOJ) announced that seven individuals believed to be part of a hacking group known as APT41 or “Wicked Panda,” including five Chinese nationals and two Malaysian nationals, have been charged in connection with a global hacking campaign that affected more than 100 companies around the world. […]