Yesterday, California voters approved a ballot initiative containing the California Privacy Rights Act of 2020. The ballot initiative significantly revises the existing California Consumer Privacy Act to create arguably the most comprehensive state privacy law in the United States. Alston & Bird has now issued a client alert explaining key impacts of this law. The […]
Financial Privacy
State Financial Regulators Issue Ransomware Mitigation Tool
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 […]
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 […]
SEC Focused on Protecting Customer Accounts from Credential Stuffing Attacks
OCIE has released a risk alert regarding credential stuffing in the context of compliance with Regulation S-P and Regulation S-ID, and is encouraging firms to both (i) review and update their policies and procedures to address the risks associated with credential stuffing and (ii) consider proactive outreach to customers regarding measures taken to safeguard their […]