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With Announcement of $1.25 Million Penalty, SEC Again Places Companies on Notice of Duty to Protect Customer Information

Jul 31 2018
Last week, the U.S. Securities and Exchange Commission announced a consent cease and desist order and sanctions against Mizuho Securities USA LLC for its failure to enforce policies and procedures designed to protect against the disclosure of material non-public information between “execution and sales traders” to other traders and externally to customers.

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In Wake of GDPR, U.S. States Continue to Strengthen Data Privacy Laws

Jun 4 2018
Now that the European Union’s General Data Protection Regulation has taken effect, many businesses are dealing with the inevitable post-compliance hangover, while others are breathing a sigh of relief that they were not impacted. For those businesses not impacted, it is important to remember that although they may not be subject to the GDPR, and there is no universal federal data protection law in the United States akin to the GDPR, there is still a significant number of federal and state data privacy laws to which they may be subject.

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Blockchain Will Change the Insurance Industry

Feb 6 2018
When the internet started to gain widespread commercial use in the early 1990s, few could have predicted the massive shift that it would have on our lives. Now, a new technology, which sits atop the internet, has the ability to cause a seismic shift in how we interact with data, and will most likely meaningfully impact virtually every person and industry.

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Version 1.1 of NIST’s Framework Reflects Changes in Cybersecurity Landscape

Jan 9 2018
On December 5, 2017, the National Institute of Standards and Technology (NIST) published Draft 2 of its Framework for Improving Critical Infrastructure Cybersecurity (the “Framework”), Version 1.1. Version 1.1 will refine, clarify, and enhance Version 1.0, which established an initial set of industry standards and best practices to help organizations manage cybersecurity risks. Draft 2 is open for public review and comment through January 19, 2018.

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U.S. District Court Dismisses FTC’s D-Link Unfairness Claim in Enforcement Action

Oct 2 2017
Morrison Mahoney partner Robert A. Stern discusses a recent U.S. District Court decision in FTC v. D-Link that may call into question the FTC’s ability to maintain cybersecurity enforcement actions under the unfairness practices prong of the unfairness doctrine against organizations that have security flaws in their products that leave consumers’ data at risk, but has not resulted in a data breach or actual harm to any consumers.

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