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 […]
Privacy & Cyber Regulatory Enforcement
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 […]
California Mandates COVID Exposure and Outbreak Reporting to Employees, Government Agencies
On Thursday, September 17, 2020, California Governor Gavin Newsom signed Assembly Bill 685 (“AB685”) into law. AB685 amends a number of portions of California’s Labor Code to address the COVID-19 pandemic. In addition to provisions that regulate reopening activities at California worksites, AB685 introduces two new COVID-related notification obligations for California employers: (1) a requirement […]