Katherine Mooney Carroll

Katherine Mooney Carroll’s practice focuses on advising U.S. and international financial institutions on U.S. regulatory matters, including recent reforms pursuant to the Dodd-Frank Act, regulatory aspects of bank M&A, cybersecurity and privacy matters, and compliance with U.S. sanctions and anti-money laundering laws.

Firm/Organization: Cleary Gottlieb Steen & Hamilton LLP

Blogs: Cleary Cybersecurity and Privacy Watch, Cleary FinTech Update, Cleary International Trade and Sanctions Watch, Cleary M&A and Corporate Governance Watch

Latest Articles

Cleary International Trade and Sanctions Watch

OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance

By Paul Marquardt, Katherine Mooney Carroll, Alexis Collins, Chinyelu Lee & Samuel H. Chang on December 5, 2018

On November 28, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) identified for the first time digital currency addresses associated with sanctioned persons. The newly sanctioned individuals, Iran-based Ali Khorashadizadeh and Mohammad Ghorbaniyan, were accused of converting digital currency payments into Iranian rial as part of a widespread ransomware scheme. Since 2015, the ransomware scheme (known as “SamSam”) has infected the data networks of corporations, hospitals, universities, and government agencies. According…

Cleary M&A and Corporate Governance Watch

CFIUS Introduces Pilot Program for Mandatory Declarations of Critical Technology Investments

By Paul Marquardt, Katherine Mooney Carroll & Chinyelu Lee on October 16, 2018

On October 10, 2018, the Department of the Treasury issued interim regulations (“Interim Regulations”) for the Committee on Foreign Investment in the United States (“CFIUS”) to conduct a pilot program implementing provisions relating to critical technologies of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), which recently amended the Exon-Florio amendments to the Defense Production Act of 1950 (together, “Exon-Florio”). The Department of the Treasury also released amendments to CFIUS’s regulations effective October…

Cleary M&A and Corporate Governance Watch

Congress Passes CFIUS Reform Bill

By Paul Marquardt, Katherine Mooney Carroll & Chinyelu Lee on August 7, 2018

On August 1, 2018 the U.S. Senate joined the U.S. House of Representatives in agreeing to a conference report that sent the National Defense Authorization Act for Fiscal Year 2019 (“NDAA”), which incorporated a version of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), to the U.S. President for his signature. The President is expected to sign the NDAA. FIRRMA updates the statute authorizing reviews of foreign investment by the Committee on Foreign…

Cleary Cybersecurity and Privacy Watch

California’s Groundbreaking Privacy Law: The New Front Line in the U.S. Privacy Debate

By Michael H. Krimminger, Katherine Mooney Carroll, Pamela L. Marcogliese, Jonathan S. Kolodner, Daniel Ilan, Rahul Mukhi, Alexis Collins, Gareth Kristensen, Jane C. Rosen, Martha E. Vega-Gonzalez & Anne Titus Hilby on July 13, 2018

On the heels of the European Union’s implementation of the General Data Protection Regulation (“GDPR”) and public outcry over the Cambridge Analytica scandal, on June 28, 2018, California enacted the most comprehensive data privacy law to date in the United States. The California Consumer Privacy Act of 2018 (the “CCPA”) was hastily passed by the California legislature to secure the withdrawal of an even more far-reaching measure that had qualified for the November ballot. Legislative…

Cleary Cybersecurity and Privacy Watch

CONSENT Act: Proposed Legislation a Sign of Potential U.S. Consent to Greater Privacy Protections?

By Jonathan S. Kolodner, Daniel Ilan, Katherine Mooney Carroll & Diana Yu on May 29, 2018

In the aftermath of the Facebook-Cambridge Analytica data privacy controversy, Senators Edward J. Markey (D-Mass.) and Richard Blumenthal (D-Conn.) introduced a federal data privacy bill on April 10, 2018 titled the Customer Online Notification for Stopping Edge-provider Network Transgressions Act, or the CONSENT Act (the “Act”). While the Act is unlikely to pass in the near term given the lack of a Republican sponsor, it reflects increasing attention to privacy concerns in the United States,…

Cleary Cybersecurity and Privacy Watch

Hong Kong SFC and HKMA Issue New Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading

By Katherine Mooney Carroll, Nowell Bamberger, Jonathan S. Kolodner, Rahul Mukhi & Freeman Chan on November 1, 2017

On October 27, 2017, the Hong Kong Securities and Futures Commission (“SFC”) issued Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading (the “Guidelines”), a set of baseline cybersecurity requirements that all persons licensed or registered with the SFC and engaged in internet trading will be required to implement. The Hong Kong Monetary Authority (“HKMA”) simultaneously issued a circular to CEOs of Registered Institutions requiring them to apply the Guidelines. The new guidelines…

Cleary Cybersecurity and Privacy Watch

CPFB Releases Consumer Protection Principles for Consumer-Authorized Financial Data Sharing and Aggregation

By Katherine Mooney Carroll, Diana Yu & Gareth Kristensen on October 26, 2017

On October 18, the Consumer Financial Protection Bureau (the “CFPB”) released the Consumer Protection Principles: Consumer-Authorized Financial Data Sharing and Aggregation (the “Principles”). The Principles represent a cautious step forward by the CFPB in providing guidance on how institutions holding customer accounts (such as banks) should share information with service providers, including “fintech” companies that obtain customer authorization to access their account information in order to provide services to such customers. Such data aggregation-based service…

Cleary Cybersecurity and Privacy Watch

Financial Stability Board Highlights Multiplicity of Cybersecurity Regulations in the Financial Sector

By Amélie Champsaur, Katherine Mooney Carroll & Martha E. Vega-Gonzalez on October 20, 2017

Last week, the Financial Stability Board (“FSB”) released the results of its stocktake on existing regulations and supervisory practices in G20 jurisdictions with respect to cybersecurity in the financial sector. The FSB is an international body that coordinates the work of national financial authorities and international standard-setting bodies, and the stocktake — essentially a survey — was requested by the G20 Finance Ministers and Central Bank Governors in March 2017.…

Cleary M&A and Corporate Governance Watch

Understanding the Impact of China’s Far Reaching New Cybersecurity Law

By Ling Huang, Daniel Ilan, Katherine Mooney Carroll & Zheng (Jonathan) Zhou on October 5, 2017

As the implementation of China’s first comprehensive cybersecurity law (the “CCL”) progresses, concern is mounting in the international business community regarding the law’s expansive scope, prescriptive requirements and lack of clarity on a range of critical issues. Vocalizing such concern, on September 25, 2017, the United States government asked China to halt its implementation of the CCL and highlighted potential issues with the CCL to members of the World Trade Organization. Since the CCL’s passage,…

Cleary International Trade and Sanctions Watch

Understanding the Impact of China’s Far Reaching New Cybersecurity Law

By Ling Huang, Daniel Ilan, Katherine Mooney Carroll & Zheng (Jonathan) Zhou on October 5, 2017

Katherine Mooney Carroll

OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance

CFIUS Introduces Pilot Program for Mandatory Declarations of Critical Technology Investments

Congress Passes CFIUS Reform Bill

California’s Groundbreaking Privacy Law: The New Front Line in the U.S. Privacy Debate

CONSENT Act: Proposed Legislation a Sign of Potential U.S. Consent to Greater Privacy Protections?

Hong Kong SFC and HKMA Issue New Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading

CPFB Releases Consumer Protection Principles for Consumer-Authorized Financial Data Sharing and Aggregation

Financial Stability Board Highlights Multiplicity of Cybersecurity Regulations in the Financial Sector

Understanding the Impact of China’s Far Reaching New Cybersecurity Law

Understanding the Impact of China’s Far Reaching New Cybersecurity Law

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