On June 27, 2023, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) released its final rule (“Final Rule”) implementing penalties for information blocking.
The Final Rule codifies the prohibition on “information blocking” introduced by the 21st Century Cures Act (“Act”), which was…
On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed Amendments”), while simultaneously issuing two additional cybersecurity-related rule proposals and re-opening the comment period for its previously proposed cybersecurity risk management…
On January 1, 2021, Congress enacted the Corporate Transparency Act as part of the Anti-Money Laundering Act of 2020 to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity.” FinCEN issued the final rule on Beneficial Ownership…
Last fall, the United States Department of Justice (“DOJ”) launched its Civil Cyber-Fraud Initiative (“CCFI”) as part of its effort to “combat new and emerging cyber threats to the security of sensitive information and critical systems.” Led by the Civil Fraud Section of DOJ’s Commercial Litigation Branch, the CCFI leverages…
During a much anticipated Open Commission Meeting announced by Commission Chair Lina M. Khan, the Federal Trade Commission (“FTC”) voted in favor of issuing one new policy statement and one new report to Congress.
First, the Commission unanimously voted in favor of issuing a policy statement on FTC initiatives…
The California Privacy Protection Agency (the “Agency”) released draft regulations to the California Privacy Rights Act (“CPRA”) on May 31, 2022 (the “Proposed Regulations”). The Proposed Regulations are drafted as comments to the California Attorney General’s regulations for the California Consumer Privacy Act, California’s landmark privacy law, which was amended…
The Department of Health and Human Services (“HHS”) has issued a formal request for information from the public about how regulated entities are implementing industry recognized security practices. The request for information represents a chance for the private sector to contribute to HHS regulation. Interested parties have until June 6…
Since the EU General Data Protection Regulation (“GDPR”) came into effect in May 2018 there have been numerous high-profile enforcement actions (~US$880m is the largest GDPR fine to-date) and private litigation (including class-action type claims). Notable fines have included the ~US$25m fine levied in October 2020 by the…
This website uses third party cookies, over which we have no control. To deactivate the use of third party advertising cookies, you should alter the settings in your browser.
