Comments Sought on Proposed Rulemaking: Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers
On December 15, 2020, the U.S. Federal Deposit Insurance Corporation (FDIC) approved and the federal banking agencies jointly announced on December 18 a notice of proposed rulemaking, Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers (NPR).1 The NPR is a joint proposal by the Office … Read More
European Union Implements Changes to Export Control Rules
The EU Dual-Use Regulation regulates exports outside the EU, transfers inside the EU, transit through the EU and the brokering of certain sensitive goods, services, software and technology (referred to as “items”) that are considered “dual-use.” Dual-use items have both military and civil applications. The EU has updated its export … Read More
All Buttoned Up: The California AG Proposes Additional CCPA Regulations
On December 10, 2020, the California Attorney General (“AG”) proposed additional edits to the CCPA Regulations. These changes both build upon the updates that were proposed on October 12, 2020, and add some new content. All of the newly proposed changes relate to the right to opt-out of the sale … Read More
CPRA’s Impact on CCPA Enforcement and Compliance
*This article originally appeared the Daily Journal on November 20, 2020
The passage of Proposition 24, the California Privacy Rights Act (CPRA), amends 2018’s California Consumer Privacy Act (CCPA) by creating the nation’s first data privacy enforcement agency and expanding consumers’ rights with respect to their personal information. In this … Read More
Important Changes to the Singapore Data Privacy Regime
On November 2, 2020, Singapore’s legislature finally approved amendments to the Personal Data Protection Act (PDPA). The changes become law once a government gazette is passed (possibly before the end of 2020). If you operate in Singapore, handle Singapore data, or maintain a server in Singapore, it is crucial that … Read More
European Commission Proposes Revised Standard Contractual Clauses
The European Commission (EC), on 12 November 2020, published a draft decision implementing revised Standard Contractual Clauses (draft SCCs) – (the EC’s Draft). The EC’s Draft was published following the Court of Justice of the European Union’s (CJEU) decision in Data Protection Commissioner v Facebook Ireland Ltd and Maximillian Schrems… Read More
European Data Protection Board Issues Schrems II Recommendations
Following the Court of Justice of the European Union’s (“CJEU”) decision in Data Protection Commissioner v Facebook Ireland Ltd and Maximillian Schrems on 16 July 2020 (“Schrems II”), the European Data Protection Board, tasked with overseeing compliance with the GDPR (“EDPB”), on 11 November 2020 issued its anticipated … Read More
TRM Podcast on DOJ’s Cryptocurrency Enforcement Framework features Sidley Partner Sujit Raman
Sidley’s newest partner, Sujit Raman, former U.S. Associate Deputy Attorney General at the Department of Justice (DOJ), was among three panelists on the TRM Talks inaugural podcast, titled “Unpacking DOJ’s Crypto Enforcement Framework.” The panel discussed the DOJ’s recently-published Cryptocurrency Enforcement Framework on legitimate uses of cryptocurrencies, the inherent … Read More
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
An Early Recap of Privacy in 2020: A US Perspective
*This article was adapted from “Global Overview,” appearing in The Privacy, Data Protection and Cybersecurity Law Review (7th Ed. 2020)(Editor Alan Charles Raul), published by Law Business Research Ltd., and first published by the International Association of Privacy Professionals Privacy Perspectives series on September 28, 2020.
Privacy, like everything … Read More