On May 12, 2025, the Federal Trade Commission’s Rule on Unfair or Deceptive Fees took effect, thereby thrusting the United States’ primary regulator of unfair or deceptive practices once more into the spotlight. But the spotlight given to the FTC rule, which only applies to the short-term lodging and live-event ticketing industries, has obscured the
On October 11, 2024, the United States Department of Defense (DOD) published a final rule implementing its Cybersecurity Maturity Model Certification (CMMC) program, which is designed to verify that defense contractors are adequately protecting sensitive information from cybersecurity threats. The CMMC applies to contractors who process, store, or transmit Controlled Unclassified Information (CUI) or Federal
A significant shift in cybersecurity compliance is on the horizon, and businesses need to prepare. Starting in 2024, organizations will face new requirements to report cybersecurity incidents and ransomware payments to the federal government. This change stems from the U.S. Department of Homeland Security’s (DHS) Cybersecurity Infrastructure and Security Agency (CISA) issuing a Notice of
The government’s announcement of renewed emphasis on cybersecurity enforcement has spawned recent million-dollar enforcement actions. Continued government attention on cybersecurity promises a treacherous enforcement environment in 2023 and beyond.
Several recent government initiatives have focused on cybersecurity enforcement. Towards the end of 2021, the Department of Justice announced a Civil Cyber-Fraud Initiative to use the
On February 1, 2022, the United States District Court for the Eastern District of California ruled that a False Claims Act (FCA) case against defense contractor Aerojet Rocketdyne Holdings and Aerojet Rockdyne Inc. (collectively “Aerojet”) could go forward on triable issues of fact as to whether noncompliance with government cybersecurity requirements are material to the
On March 18, 2021, the Department of Energy’s (DOE) Office of Cybersecurity, Energy Security, and Emergency Response (CESER) announced three new research programs that are “designed to safeguard and protect the U.S. energy system” from potential cyberattacks. The DOE also announced a 100-day plan to address cybersecurity risks to the U.S. electric system. Not to
On December 15, 2020, the FTC announced a proposed settlement with Ascension Data & Analytics, LLC, a mortgage industry analytics company, related to alleged violations of the Gramm-Leach-Bliley Act’s (GLBA) Safeguards Rule. In particular, the FTC claimed that Ascension Data & Analytics’ vendor, OpticsML, left “tens of thousands of consumers[’]” sensitive personal information exposed “to