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KYC in a Digital World, How New Sanctions and AML Expectations Have Upped the Stakes and What You Need to Do About it
“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent months. For example, in response to Russia’s...
Amid a Minefield of Sanctions and Export Controls, Here's How to Provide Aid to Ukraine
Over the past week, the Biden Administration has announced unprecedented sanctions and export controls against Russia in response to its unprovoked invasion of Ukraine. As the State Department pledges an additional $350 million in military and humanitarian support for Ukraine...
Cyber Siren Warning - When State Actors Attack
Russia began a physical invasion of Ukraine Wednesday night, and as the United States responded with sanctions, the threat of cyberattacks against American companies became more acute. Major American businesses – from banks to critical infrastructure companies – are preparing...
Ransomware: An Enterprise Risk for the Unprepared
For a company with robust data protection and recovery practices, a ransomware attack may cause a few extra headaches, but it won’t wipe the company out. Companies without those protections in place, however, risk allowing ransomware to bankrupt their entire...
FTC Warns Use of "Full Legal Authority" on Companies That Ignore Log4j Risk
The Federal Trade Commission (FTC) sent a strong message to organizations in the wake of the Log4j security vulnerability : patch now or face regulatory scrutiny and potential legal action. In the notice issued last week , the FTC acknowledged...
CPRA Countdown: It's Time to Brush Up on California's Latest Data Privacy Law
On November 3, 2020, California voters approved Proposition 24, a ballot initiative which enacted the California Privacy Rights Act (“CPRA”). The CPRA amends the California Consumer Privacy Act (“CCPA”), the most sweeping consumer data protection law in the U.S. This...
Patch Up – Log4j and How to Avoid a Cybercrime Christmas
A vulnerability so dangerous that Cybersecurity and Infrastructure (CISA) Director Jen Easterly called it “one of the most serious [she’s] seen in [her] entire career, if not the most serious” arrived just in time for the holidays. On December 10...
UAE Law Regarding the Protection of Personal Data
The United Arab Emirates joins Saudi Arabia by passing Federal Decree-Law No (45) of 2021 Regarding the Protection of Personal Data (“PPD Law”) to bring comprehensive data protection legislation to another country in the MENA region. Notably the PPD broadly...
Government Enforcement and Investigations Year-In-Review: The Administration Has Moved Its Pieces into Place
On Monday, President Biden released the United States Strategy on Countering Corruption , which details how the United States will work “domestically and internationally, with governmental and non-governmental partners, to prevent, limit, and respond to corruption and related crimes.” It...
Virginia Is For [Data Privacy] Lovers: Introduction to Virginia's New Consumer Protection Law
On January 1, 2023, the Virginia Consumer Data Protection Act (VCDPA) will go into effect. With passage of the law earlier this year, Virginia joined Colorado and California as the only states to enact comprehensive privacy legislation. The VCDPA includes...
Colorado Privacy Act: New protections for consumers in the Centennial State
On July 1, 2023, the Colorado Privacy Act (CPA) will go into effect as the third state law generally governing consumer data privacy and was the second enacted in 2021. If you do business with consumers in Colorado, regardless of...
The IRS Is Mining for Crypto Account Holders
For years, the cryptocurrency wallets of U.S. taxpayers have existed in a reporting gray zone. However, as it becomes clear that crypto asset transactions are not slowing down, the Internal Revenue Service (IRS) has signaled its expanded focus on regulation...
2021 Year-in-Review – U.S. State Privacy Legislation
The COVID-19 pandemic has rapidly accelerated our reliance on digital services and platforms, which brings new challenges and expectations for data privacy. But, to date, there has been little movement towards all-encompassing federal privacy legislation. Therefore, the issue of consumer...
DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You
In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a layer of structure and coordination to the DOJ’s...
OFAC Ransomware Update
On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet another initiative relating to the U.S. Treasury...