On July 30, 2020, the European Council announced sanctions against six individuals and three organizations for their involvement in a series of cyber-attacks that have caused significant damage in the EU and around the world over the last several years. The announcement follows the EU’s adoption last year of Decision (CFSP) 2019/797, which established the […]
Cybersecurity
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 […]
Georgia Supreme Court Clarifies There Is No Duty to Safeguard Personal Information from a Data Breach
The Georgia Supreme Court recently issued a decision holding that there is no duty to safeguard personal information from a data breach under Georgia law. Georgia Department of Labor v. McConnell involved the accidental disclosure of a spreadsheet that contained the name, social security number, home telephone number, email address, and age of thousands of […]
DOJ Releases “Best Practices for Victim Response and Reporting of Cyber Incidents,” Version 2.0
On September 27, 2018, the Department of Justice Computer Crime and Intellectual Property (CCIPS) Cybersecurity Unit released Version 2.0 of its “Best Practices for Victim Response and Reporting of Cyber Incidents.” Originally issued in 2015, the updated guidance seeks to help organizations better equip themselves to be able to respond effectively and lawfully to cyber […]
SEC Brings First Enforcement Action for Violation of the Identity Theft Red Flags Rule
On September 26, 2018, the SEC brought its first ever enforcement action for violations of Regulation S-ID (the “Identity Theft Red Flags Rule”), 17 C.F.R. § 248.201, in addition to violations of Regulation S-P, 17 C.F.R. 30(a) (the “Safeguards Rule”). Regulation S-ID and Regulation S-P apply to SEC-registered broker-dealers, investment companies, and investment advisers, and […]