Sullivan & Cromwell Discusses Warnings to Bank CEOs About Cybersecurity Risks of Anthropic’s New AI Model

By Nicole Friedlander, Nader A. Mousavi, Mehdi Ansari, Anthony J. Lewis and Maximilian Y. M. Frank April 23, 2026 by jlucero

On April 7, 2026, Treasury Secretary Scott Bessent and Federal Reserve Chair Jerome Powell convened an urgent, closed-door meeting with the CEOs of some of the nation’s largest banks to discuss the cybersecurity risks posed by Anthropic’s newly announced AI …

Corporate Oversight in the Age of Artificial Intelligence

By Pierluigi Matera March 10, 2026 by renholding

Corporate oversight under Delaware law rests on the two bases for liability, each identified in In re Caremark International Inc. Derivative Litigation (“Caremark”) and reaffirmed in Stone v. Ritter. The first is a failure to implement any reporting …

Cleary Gottlieb Discusses the Shifting SEC Enforcement Landscape

By Tom Bednar, Matt Solomon and Katie McGuire February 16, 2026 by renholding

Fiscal year 2025 was a year of extremes in terms of the number of enforcement actions brought by the Securities and Exchange Commission (SEC). During the first quarter of fiscal year 2025 (October through December 2024), the SEC reported a …

Covington Discusses NY Financial Services Department Guidance on Data Privacy and Cybersecurity

By Micaela McMurrough, Caleb Skeath, Miranda Rutherford & Analese Bridges November 7, 2025 by jlucero

On October 21, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter (the “Guidance”) highlighting the cybersecurity risks related to Covered Entities’ use of Third-Party Service Providers (“TPSPs”) and providing strategies to address these risks. …

The Gap Between Cybersecurity Oversight and Boardroom Expertise

By Michelle R. Lowry, Anthony Vance and Marshall D. Vance August 13, 2025 by renholding

Following a string of high-profile data breaches and other cybersecurity failures, investors and regulators increasingly expect corporate directors to monitor cyber risk. But what does board oversight of cybersecurity look like in practice, and is it effective? In a recent …

Sullivan & Cromwell Discusses SEC Withdrawal of 14 Proposed Rules

By Colin Lloyd, Eric Diamond, Malou (Marie-Louise) Huth, Aaron Levine and Natasha Vasan June 23, 2025 by renholding

On June 12, the SEC withdrew 14 proposed rules stating that it did not intend to issue final rules with respect to the proposals and that if the SEC decides to pursue future regulatory action in any of these areas, …

Cleary Gottlieb Discusses Effective Board Oversight as AI Evolves

By Angela L. Dunning, Daniel Ilan, David Lopez, Marcela Robledo and Synne D. Chapman February 5, 2025 by renholding

Deployment of generative AI expanded rapidly across many industries in 2024, leading to broadly increased productivity, return on investment and other benefits. At the same time, AI was also a focus for lawmakers, regulators and courts. There are currently 27 …

Morrison & Foerster Discusses Final Biden Cybersecurity Order

By Tina Reynolds and Markus Gerhard Speidel January 28, 2025 by eorozco

Citing the threats posed by foreign adversaries and criminal organizations, and seeking enhanced accountability for companies that provide software and cloud services to the federal government, the Biden administration released a new, sweeping Executive Order (“E.O.”) on cybersecurity, signing the …

SEC Announces Enforcement Results for Fiscal Year 2024

By Securities and Exchange Commission November 25, 2024 by renholding

The Securities and Exchange Commission announced on November 22 that it filed 583 total enforcement actions in fiscal year 2024 while obtaining orders for $8.2 billion in financial remedies, the highest amount in SEC history.

The 583 enforcement actions represent

…

Debevoise & Plimpton Discusses Key Considerations for the 2024 Annual Reporting Season

By Eric T. Juergens, Benjamin R. Pedersen, Paul M. Rodel, Alice Gu and Amy Pereira November 22, 2024 by ngodridge

As November comes to an end, the busy annual reporting and proxy season begins for many public companies. In this Client Update, we highlight key considerations for public companies when preparing their annual reports on Form 10-K or Form 20-F, …

Wachtell Lipton Offers Summer Takeaways in SEC Enforcement

By John F. Savarese, Wayne M. Carlin and David B. Anders September 5, 2024 by renholding

With the Labor Day holiday now behind us, it is a good time to review the SEC’s active enforcement docket and to look ahead to likely areas of continuing enforcement attention as we head into the fall. The record over …

Skadden Discusses New UK Government’s AI and Cybersecurity Reforms

By Nicola Kerr-Shaw and Aleksander J. Aleksiev August 9, 2024 by renholding

Last month the new Labour government in the UK announced in the King’s Speech that it will introduce new artificial intelligence (AI) rules alongside cybersecurity and digital information bills. A brief overview of these developments is set out below.

Artificial

…

SEC Corporation Finance Director Speaks on the State of Disclosure Review

By Erik Gerding June 25, 2024 by renholding

Good afternoon.[1] I appreciate the opportunity to speak with you again today as part of the Corp Fin Workshop. I wanted to make a few remarks about the important work being done in the Division’s Disclosure Review Program and

…

SEC Corporation Finance Chief Addresses Disclosure of Cybersecurity Incidents

By Erik Gerding May 24, 2024 by renholding

The cybersecurity rules that the Commission adopted on July 26, 2023[*] require public companies to disclose material cybersecurity incidents under Item 1.05 of Form 8-K.[1] If a company chooses to disclose a cybersecurity incident for which it has …

Skadden Discusses a Board’s Role in Oversight of Cybersecurity Risks

By Anita B. Bandy, Brian V. Breheny, Raquel Fox, William Ridgway and David A. Simon February 28, 2024 by renholding

Key Points

New SEC rules from 2023 require public companies to report material cybersecurity incidents promptly and detail their cybersecurity risk management strategies in annual reports — requirements that increase the risk of litigation over misstatements relating to cybersecurity.
The

…

Cleary Gottlieb Discusses AI’s Risks for Boards and Managers

By David Lopez, Adam Fleisher, Daniel Ilan, Benet O’Reilly and Synne Chapman February 20, 2024 by renholding

Artificial intelligence (AI)[1] was the biggest technology news of 2023. AI continues to revolutionize business in big and small ways, ranging from disrupting entire business models to making basic support functions more efficient. Observers have rightly focused on the …

Wachtell Lipton Discusses Key Issues in Corporate Governance for 2024

By Martin Lipton, Steven A. Rosenblum, Karessa L. Cain and Carmen X.W. Lu January 10, 2024 by renholding

Over the past year, expectations for directors have continued to evolve, bringing new challenges and responsibilities to the boardroom. The remarkable speed, volume and proliferation of channels through which information travels today continue to place more scrutiny on boards and

…

Morrison & Foerster Discusses Impact of New York Amendments to Cybersecurity Regulation

By Miriam Wugmeister, Carrie Cohen, Kristen Mathews and Nathan Reilly December 15, 2023 by renholding

The New York Department of Financial Services (NYDFS) has finalized amendments (“Amended Regulation”) to its cybersecurity rule (“Cybersecurity Rule”) that applies to financial institutions licensed by the NYDFS. This comes after a series of proposed amendments (see our client …

Debevoise Discusses SEC’s Division of Enforcement Year-End Results

By Kara Brockmeyer, Andrew Ceresney, Robert Kaplan, Julie Riewe and Mary Jo White November 30, 2023 by renholding

On November 14, 2023, the U.S. Securities and Exchange Commission’s (“SEC” or “Commission”) Division of Enforcement (“Division”) announced its enforcement results for fiscal year (“FY”) 2023.[1] Disgorgement and penalties were the second highest in the SEC’s history at just …

SEC Announces Enforcement Results for Fiscal Year 2023

By Securities and Exchange Commission November 15, 2023 by renholding

The Securities and Exchange Commission announced that it filed 784 total enforcement actions in fiscal year 2023, a 3 percent increase over fiscal year 2022, including 501 original, or “stand-alone,” enforcement actions, an 8 percent increase over the prior fiscal …

1 2 3 … 6 Next »

The CLS Blue Sky Blog

Columbia Law School's Blog on Corporations and the Capital Markets

cybersecurity