By

Michael R. Roberts

24 June 2021

SEC Announces Settled Charges Against First American for Cybersecurity Disclosure Controls Failures – Lessons Learned

On June 15, 2021, the SEC announced settled charges against First American Title Insurance Company (First American) for disclosure controls and procedures violations related to a cybersecurity vulnerability that exposed sensitive customer information.1  Without admitting or denying the SEC’s findings, First American agreed to a cease-and-desist order and to … Read More

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08 October 2020

Office of Foreign Assets Control: Making or Facilitating Ransomware Payments May Violate U.S. Sanctions

On October 1, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an advisory that highlights the risk of potential U.S. sanctions law violations if U.S. individuals and businesses comply with ransomware payment demands.1

Ransomware attacks use malware, often injected through phishing schemes, to encrypt a … Read More

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20 August 2020

Third Time’s the Charm: CCPA Regulations Finally Approved With Limited Substantive Changes from June 2020 Version

On August 14, 2020, California’s Office of Administrative Law approved and filed with the California Secretary of State final regulations implementing the California Consumer Privacy Act.  The regulations, drafted by California’s Office of the Attorney General (OAG), went through three rounds of changes during the rulemaking process and were finally … Read More

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19 August 2020

Historic Charges: First Enforcement Action Filed by New York Department of Financial Services Under Cybersecurity Regulation

On July 21, 2020, the New York State Department of Financial Services (NYDFS or the Department) issued a statement of charges and notice of hearing (the Statement) against First American Title Insurance Company (First American) for violations of the Department’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R. Part 500 … Read More

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04 June 2020

CCPA Enforcement Date Rapidly Approaching: California Attorney General Proposes Regulations for Final Review With July 1, 2020 Less Than One Month Away

On June 1, 2020, California’s Office of the Attorney General (“AG”) moved one step closer to finalizing the California Consumer Privacy Act (“CCPA”) regulations when the AG submitted proposed final regulations for review and approval by California’s Office of Administrative Law (“OAL”).  This submission signals the end of the AG’s … Read More

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07 May 2020

In Midst of COVID-19 Pandemic, Senators Propose Privacy Bill Aimed At Businesses’ Use of Consumer Data

On April 30, 2020, four Republican Senators announced plans to introduce the COVID-19 Consumer Data Protection Act.  The four Senators, John Thune (R-S.D), Roger Wicker (R-Miss.), Jerry Moran (R-Kan.), and Marsha Blackburn (R-Tenn.), are all Members of the Commerce Committee, with Wicker the Committee’s chair.

According to the April 30 … Read More

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10 April 2020

CCPA Marches On: California Attorney General Proposes Further Revisions to CCPA Regulations, Industry Pleads for Enforcement Delay Amid COVID-19 Crisis

While the world seems to have ground to a halt in so many ways, time still marches on, and along with it, the California Consumer Privacy Act (“CCPA”) enforcement date (July 1, 2020) inches ever closer.   On March 11, 2020, the California Attorney General (“AG”) released the third turn of … Read More

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12 February 2020

A February 2020 Surprise: California Attorney General Proposes Significant Revisions to CCPA Regulations

Just as companies were starting to recover from their exertions to put in place California Consumer Privacy Act (“CCPA”) compliance programs before the law’s January 1, 2020 entry into force, the California Attorney General (“AG”) provided an early February surprise.  CCPA watchers long expected that the AG would revise the … Read More

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29 January 2020

NIST Releases Version 1.0 of Privacy Framework to Help Organizations Manage Privacy Risks and Improve Protection of Personal Data

With issues around the collection and handling of personal data becoming the focus of increased scrutiny among regulators, policymakers, and consumers, interest has continued to grow among organizations to better understand and address privacy risk.  Seeking to support innovation in the market and to accommodate the increasingly global nature of … Read More

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03 September 2019

Carpenter and Everything After: The Supreme Court Nudges the Fourth Amendment into the Information Age

*This article was first published by the American Bar Association Infrastructure and Regulated Industries in Summer 2019.

Every year, as the calendar turns to June, the legal community looks to the Supreme Court. Eager to get to the Term’s end, the Justices rush to complete all of the outstanding opinions. … Read More

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