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 […]
Privacy
California Department of Justice Releases Post-Finalization Modifications to CCPA Regulations
On October 12, 2020, the California Department of Justice (“Department”) released its first set of proposed post-finalization modifications to the California Consumer Privacy Act Regulations (the “CCPA Regulations”). As many businesses know, the CCPA Regulations were finalized on August 14, 2020. The Department styled these new modifications as a “Third Set of Proposed Modifications” to […]
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 […]