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
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Standing to Sue: Is Theft of Drivers’ License Numbers Sufficient to Allege Imminent Threat of Future Harm?
Judge Jeffrey White of the Northern District of California recently dismissed a putative class action lawsuit in which plaintiffs claimed they faced an imminent threat of future of harm in the form of identity theft and fraud because their personal…
Travelling outside the EU: French Data Protection Authority Publishes a Checklist to Secure Phones and Laptops
Amid fresh fears about data protection, on November 14th, France’s data protection authority, the Commission Nationale de l’Informatique et des Libertes (CNIL) published a checklist of recommended actions travellers should take to secure phones, computers and tablets when travelling outside…
HHS Bulletin: Covered Entities’ Disclosure of PHI Collected via Online Tracking Technologies Falls under HIPAA
On December 1, 2022, the Office for Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) issued a Bulletin to highlight the obligations of HIPAA-covered entities and business associates when using “online tracking technologies,” or what OCR…
Paying the Ransom in Response to a Ransomware Attack can Sometimes Backfire
One of the key decisions that needs to be made in the aftermath of a successful ransomware attack is whether or not the victim organization can or should pay the ransom. Of course, there are many considerations that go into…
EU-U.S. and UK-U.S. Data Transfer Deals Advance with White House Executive Order
A new legal mechanism to allow for transfers of personal data between the EU and the U.S. is now advancing after an October 7th, 2022 Executive Order was issued by U.S. President Biden (the “Executive Order”). The new mechanism is…
Held to Ransom: How Cyberattacks Can Become a Legal and Regulatory Odyssey for a Private Investment Fund
Where business-critical information or platforms are at stake, many commercial parties will seriously consider immediately paying the ransom hoping to regain control of operations, secure client data and avoid continued business disruption and negative publicity. However, businesses may wish to…
Happy “Labor …” More Privacy Rights for Employees: California Legislature Closes Session Without Extending Employee and B2B Data Exemptions Under the CCPA
As summer nears its end, uncertainty and complexity lie ahead for many companies as they evaluate how to operationalize compliance with the California Privacy Rights Act (CPRA), existing California employment laws and potentially the passage of a federal privacy law,…
Message Sent! California Attorney General Announces $1.2 Million CCPA Settlement with Retailer and Its Focus on the Sale of Customer Information
On August 24, 2022, California Attorney General (AG) Rob Bonta announced a settlement with beauty products retailer, Sephora USA, Inc. (“Sephora”), resolving claims that Sephora violated the California Consumer Privacy Act (CCPA) for, among other things, failing to disclose to…
DOJ’s Civil Cyber-Fraud Initiative Secures More Than $9 Million in Two False Claims Act Settlements for Alleged Cybersecurity Violations
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…