On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of Regulation S-P that arose in the context of a data disposal process, imposing a $35 million penalty. Specifically, the SEC […]
Privacy & Cyber Regulatory Enforcement
CISA Issues Request for Information Prior to Required CIRCIA Rulemaking
On September 12, 2022, the Cybersecurity and Infrastructure Security Agency (CISA) issued a request for information (RFI) seeking input from stakeholders on the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). Signed by President Biden in March, CIRCIA requires CISA to develop and implement regulations requiring covered entities to report information about covered […]
Sephora Ordered to “Make-Up” for CCPA Violations
On August 24, 2022, California Attorney General Rob Bonta announced a $1.2 million dollar settlement with Sephora to account for alleged violations of the California Consumer Privacy Act (CCPA). This is the first CCPA enforcement action taken by the California AG that has resulted in a fine and settlement. The Attorney General’s Complaint alleged Sephora […]
FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security
On August 22, 2022, the Federal Trade Commission (FTC) published its advance notice of proposed rulemaking (ANPR) to request public comment on commercial surveillance and data security practices. The ANPR comes at the same time as Congress is considering the federal American Data Privacy and Protection Act (ADPPA). The FTC seeks public comment on a […]
Recent Exploits of Blockchain Bridges Highlight Need for Cybersecurity in Crypto and Risk of Liability
According to recent media reports there have been several instances of blockchain bridges being hacked this year, including reports on August 2 that a bridge lost close to $200 million to upwards of 40 hackers who exploited a bug in its protocol, and reports in June that another bridge lost $100 million from hackers allegedly […]