OCC

What’s the OCC Banking Regulatory Outlook for 2022?

As the year’s end approaches, the US Office of the Comptroller of the Currency (OCC), a primary US banking regulator, has published its Banking Supervision Operating Plan for 2022. As you might expect, much of the OCC’s focus is on managing the repercussions of the pandemic and the resulting economic, financial, operational, and compliance implications. The specific points it…
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Privacy

U.S. Privacy Law: Past, Present and Future

Privacy law is a hot topic for legislatures in the United States at both the state and federal levels. With the advent of influential laws from international governments, including the European Union, the lack of significant privacy regulation in the U.S. has become glaringly apparent. In this article, we discuss the history of privacy regulation…
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Cryptocurrency

DOJ Announces National Cryptocurrency Enforcement Team

On October 6, the Department of Justice (“DOJ”) announced the creation of a National Cryptocurrency Enforcement Team (“NCET”).  The DOJ press release is set forth in part below, without further commentary, other than to observe that the NCET’s stated goals are to address issues on which we repeatedly have blogged:  crypto exchangers and their AML obligations; the…
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Ransomware

New Ransomware Guidance Issued

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new ransomware guidance, discouraging companies and citizens from paying ransoms. The Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments is the latest step taken by the Biden Administration to curb the increase in ransomware attacks. In…
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Data Security

The Impact of Data Security Incident Trends on Commercial Transactions

The 2021 edition of BakerHostetler’s annual Data Security Incident Response Report – a report based on the firm’s experience with data security incident response and litigation over the past year – features a number of important insights previously covered on this blog including trends in global breach notification, healthcare industry risks and ransomware. The Report is a helpful tool for companies…
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Cybersecurity

How Federal Agencies are Approaching Cybersecurity Training Programs

Due in part to priorities being set by the Biden administration, many government organizations are taking steps to emphasize the importance of cybersecurity. A big part of that means implementing training programs as ways to better handle cybersecurity threats, and a handful of proposed legislations aims to do just that. With cybersecurity becoming a national…
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SCC

How to Comply With the EU’s New SCC Framework

Since the Schrems 2.0 decision, any organization involved in the international transfer of personal data between the EU and America has been eagerly awaiting a new set of Standard Contractual Clauses (SCCs). In short, the SCCs previously used for such transfers were written before the implementation of the EU’s General Data Protection Regulation (GDPR), so…
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