New Know-Your-Customer and Reporting Rules Proposed for Cloud Providers: Five Key Takeaways
Last week, the U.S. Department of Commerce published a notice of proposed rulemaking (NPRM) implementing Executive Orders (EO) 13984 and 14110 to prevent “foreign malicious cyber actors” from accessing U.S. infrastructure as a service products1 (IaaS Rule). The IaaS Rule seeks to strengthen the U.S. government’s ability to track “foreign malicious cyber actors” who have relied on U.S. IaaS products to steal intellectual property and sensitive data, engage in espionage activities, and threaten national security by attacking critical infrastructure.
Uber Data Breach Results in Corporate Cooperation and Executive Conviction
On October 5, 2022, a federal jury in the Northern District of California convicted former Uber Chief Security Officer Joseph Sullivan of obstructing a federal proceeding and misprision of a felony for his role in deceiving management and the federal government to cover up a 2016 data breach that exposed personally identifiable information (“PII”) of approximately 57 million users, including approximately 600,000 drivers’ license numbers, of the ride-hailing service. Sullivan, a former federal prosecutor, appears to be the first corporate executive criminally prosecuted—let alone convicted—for his response to a data security incident perpetrated by criminals. Sullivan faces a maximum of five years in prison for the obstruction charge, and a maximum three years in prison for the misprision charge.
