Enforcement

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As we previewed in our prior Legal Update, the Federal Trade Commission (“FTC”) warned businesses of its stance on the use and collection of biometric information in a May 2023 policy statement. Now, an enforcement action filed earlier this week offers insight into the potential consequences for businesses that do not comply with the…

On March 9, 2023, the Securities and Exchange Commission (“SEC”) announced that Blackbaud Inc. (“Blackbaud”) agreed to pay $3 million to settle charges for alleged misleading disclosures about its 2020 ransomware attack and for alleged disclosure control failures.1

Blackbaud, a South Carolina-based company that provides data management software to colleges, universities, and non-profit organizations,…

This past summer’s string of cyber enforcement actions signals that cybersecurity has become a top priority for the US Securities and Exchange Commission (“SEC”). These enforcement actions highlight the SEC’s scrutiny of written documentation and disclosures following incidents. In this National Cybersecurity Awareness Month Legal Update, we discuss the SEC’s recent cyber enforcement actions, as…

In remarks on October 13, 2021, at the Cybersecurity and Infrastructure Security Agency (“CISA”) National Cybersecurity Summit, Acting Assistant Attorney General Brian Boynton fleshed out the Department of Justice’s (“DOJ”) thinking regarding the nature of the cybersecurity failures that are likely targets for potential False Claims Act (“FCA”)1 enforcement under the Civil Cyber-Fraud Initiative…

The Securities and Exchange Commission (SEC) established its Cyber Unit in 2017 to combat a variety of cyber-related misconduct, including market manipulation, unauthorized access to non-public information and financial accounts, threats to financial market infrastructure, and other misconduct.
To read this complete article visit Reuters.

On October 6, 2021, the US Department of Justice (DOJ) announced a new initiative to address cyber-fraud and that focuses on government contractors. Specifically, DOJ has launched a “Civil Cyber-Fraud Initiative” (Initiative), which will combine DOJ’s “expertise in civil fraud enforcement, government procurement and cybersecurity to combat new and emerging cyber threats to the security…

Oil and gas companies should anticipate a more vigorous enforcement environment during President Biden’s term, with anti-corruption and sanctions enforcement expected among some of the key areas of focus. In addition, companies should expect close scrutiny of the industry’s management of cyber risks, along with increased regulatory and litigation risk.

To help you navigate the…

In June 2019, the UK Information Commissioner’s Office (“ICO“) produced a report on the advertising industry’s use of adtech and real time bidding (“RTB“) and whether UK data protection and e-marketing legislation was being complied with. The report criticised parts of the sector for not doing enough to safeguard personal data,…

On September 26, 2018, the US Securities and Exchange Commission (“SEC”) brought and settled charges against a registered broker-dealer/investment adviser (the “Registrant”) for allegedly violating the Gramm-Leach-Bliley Act Safeguards Rule (Regulation S-P) and the Identity Theft Red Flags Rule (Regulation S-ID).1 The Registrant allegedly violated the SEC’s rules by failing to implement appropriately designed…

On June 6, 2018, the US Court of Appeals for the Eleventh Circuit ruled in favor of LabMD in the medical testing company’s closely watched challenge to the Federal Trade Commission’s (“FTC”) data security enforcement action. While assuming that the FTC was correct that LabMD’s allegedly unreasonable security practices constituted an unfair act or practice…