On May 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated crypto mixer Blender.io as a Specially Designated National (“SDN”), marking the first time a virtual currency mixer has been sanctioned. The move is the latest in a series of sanctions designations and enforcement actions in the virtual currency

Strengthening the nation’s cybersecurity has been a top priority for the Biden administration, as reflected in its collaboration with industry, regulatory actions, and the legislation it has supported in Congress, including the Cyber Incident Reporting for Critical Infrastructure Act of 2022. Executive action has been a key tool in the Biden administration’s cyber policymaking toolkit.

On February 9, 2022, the Securities Exchange Commission (“SEC” or “Commission”) voted 3-1 to propose rules, forms and amendments concerning cybersecurity risk management, as well as registered investment adviser and fund disclosures. As we have previously discussed, the proposal under the Investment Advisers Act of 1940 (Advisers Act) and the Investment Company Act of

New draft Regulations on the Online Protection of Minors (Draft Regulations) were released by the Cyberspace Administration of China (CAC) on 14 March 2022. They update the 2016 Draft Regulations of the same name which were released for public comment but never adopted.

The latest Draft Regulations have been issued pursuant to the PRC Law

On March 29, 2022, the US federal banking regulators released instructions on how financial institutions should comply with recently adopted computer-security incident notification requirements.1 These instructions will assist financial institutions in satisfying their obligations under the new requirements once compliance is required on May 1, 2022.

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On 2 March 2022, the Cyberspace Administration of China (“CAC”) issued draft regulations on the administration of internet pop-up push notifications (the “Draft Regulations”). The Draft Regulations were issued pursuant to a number of laws, including the Cybersecurity Law.

The Draft Regulations bid to further tighten government control over the news followed a

The upshot, for busy people:

  • Realizing value and managing risk in investments and acquisitions of digital assets businesses means understanding several key areas of the target’s business—among them, cybersecurity, data privacy and regulatory positions.
  • This is particularly challenging in light of the pace of innovation in these technologies and the intersecting, evolving regulations that apply

On March 15, 2022, President Biden signed into law the Consolidated Appropriations Act, 2022, H.R. 2471. Division Y of this omnibus appropriations legislation—the Cyber Incident Reporting for Critical Infrastructure Act of 2022—will create significant new rules requiring US critical infrastructure entities to report cybersecurity incidents and ransom payments to the US government. This legislation marks

On March 9, 2022, the U.S. Securities and Exchange Commission (the “SEC”) released proposed amendments (the “Proposed Amendments”) aimed at enhancing and standardizing disclosure relating to cybersecurity risks and incidents. Under the existing regulatory framework, neither Regulation S-K nor Regulation S-X expressly requires that cybersecurity risk management procedures, cybersecurity risks or incidents be disclosed. However,

On March 9, 2022, the US Securities and Exchange Commission (SEC) voted 3-1 to propose new rules and amendments under the Securities Exchange Act of 1934 that would constitute the SEC’s first attempt to adopt specific rules to comprehensively regulate cybersecurity risk management, strategy, governance and incident reporting for public companies (“registrants”). The stated goals