On November 8, 2021, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a virtual currency exchange, Chatex, and its infrastructure support providers on the list of Specially Designated Nationals and Blocked Persons (SDN List) for
Continue Reading OFAC Ramps up Targeting of Ransomware-linked Actors and FinCEN Updates Ransomware Advisory
Cleary Cybersecurity and Privacy Watch
Global Legal Developments related to Cybersecurity Incidents, Cyber Corporate Governance and Regulation Issues, and Privacy and Data Protection Laws
Latest from Cleary Cybersecurity and Privacy Watch
UK Supreme Court Rules in Favour of Google in Data Protection Class Action Claim
On 10 November 2021, the Supreme Court of the United Kingdom handed down its much-awaited judgment in the case of Lloyd v Google LLC [2021] UKSC 50. The Supreme Court unanimously ruled that the claim, which is a representative action alleging…
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OFAC Updates Ransomware Advisory and Sanctions Virtual Currency Exchange
On September 21, 2021, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC): (i) issued an updated advisory on potential sanctions risks for facilitating ransomware payments; and (ii) designated SUEX OTC, S.R.O. (SUEX), a virtual currency exchange,…
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SEC Enforcement Action Against Poloniex Signals Heightened Scrutiny for Crypto Exchanges
On August 9, 2021, the SEC issued a cease-and-desist order against digital asset exchange Poloniex, Inc. for allegedly operating an unregistered exchange in violation of Section 5 of the Exchange Act in connection with its operation of a trading platform…
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The New Commission SCCs for Data Transfers under GDPR – More Questions than Answers?
The past few years have brought monumental changes to how we handle international data transfers from the EU. Schrems I, GDPR, Schrems II, Brexit and now the new Standard Contractual Clauses, published in June, 2021.
Here we share our views…
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The Centennial State Claims a New Number: Colorado to Become Third State in the U.S. to Enact Comprehensive “Privacy Act”
Colorado is set to become the third state in the nation to enact comprehensive privacy legislation with the passing of SB 21-190, more commonly known as the Colorado Privacy Act (“ColoPA” or the “Act”). Governor Jared Polis is expected to…
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Robinhood Sued For Failing To Protect Customers’ Accounts
Recent developments in a lawsuit have illustrated the importance of maintaining sufficient data security measures and responding adequately to data breaches, which topics are addressed in Cleary Gottlieb’s Global Crisis Management Handbook in depth. A class-action lawsuit in the Northern…
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Cryptocurrency and Other New Forms of Financial Technology: Potential Terrorist Financing Concerns and Liability
While large financial institutions have traditionally been hesitant to enter new areas of financial products, particularly virtual assets, many more banks and companies have expressed interest in virtual currencies as cryptocurrency has become increasingly mainstream. Given the use of such…
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Second Circuit Articulates Injury Standard in Data Breach Suits
Last week, the Second Circuit affirmed the dismissal for lack of Article III standing a proposed class action against a health services provider that mistakenly disclosed personally identifiable information (“PII”). In its opinion, the Second Circuit held that plaintiffs may…
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FTC to Corporate Boards: Mind Your Data Security
On April 28, 2021, the U.S. Federal Trade Commission (“FTC”) published a blog post reminding corporate boards of directors of their responsibility to oversee data security issues and ensure that consumer and employee data are protected. The FTC’s post is…
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