On January 6, 2020, the Federal Trade Commission’s (FTC) Bureau of Consumer Protection Director Andrew Smith published a blog post summarizing the agency’s “New and improved FTC data security orders,” as part of its efforts to provide “better guidance for companies” and “better protection for consumers.” Smith noted that strengthening the FTC’s orders in data […]
Privacy & Cyber Regulatory Enforcement
Wim Nauwelaerts Authors Summary of EDPB’s Guidelines of the GDPR
Wim Nauwelaerts, Brussels partner and leader of the firm’s EU Privacy and Data Protection practice, has authored a summary of the European Data Protection Board’s (EDPB) guidelines on the territorial scope of the GDPR. On November 12, 2019, the EDPB adopted the final version of its guidelines – almost one year after they had been […]
Schrems 2.0: Standard Contractual Clauses Declared Valid by EU Advocate General
The Advocate General’s Opinion of December 19, 2019 deemed valid the Standard Contractual Clauses (SCCs) adopted by the European Commission for the transfer of personal data from controllers to processors. Currently, many companies rely on SCCs as a mechanism for transferring personal data from the EU to non-EU countries in compliance with the GDPR. […]
Treasury Announces Sanctions Against Cybercriminal Group Behind ‘Dridex’ Malware, Offering Mitigation Strategies for Businesses
On December 5, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued sanctions against Evil Corp, a Russian cybercriminal organization that is known for distributing the Dridex malware. Dridex is a banking trojan that has been used to target financial institutions across the globe and has resulted in more than $100 million […]
Critical Audit Matters Disclosure Implicates Information Technology and Security
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of information security programs and information technology controls. Independent auditors have treated material weaknesses in certain information technology controls as material weaknesses in internal […]