L-R: Michael Ward, Matthew Baker and Julia Wu of Baker Botts, Palo Alto, California. Courtesy photos Bug Bounties and Ransomware Demands: Storm Clouds Ahead for In-House Counsel
In the case of data breaches, the obligation to disclose may well be clearly defined by statute. Any company under active investigation for a data breach should carefully consider its obligation to disclose additional security incidents to regulators.
November 07, 2022 at 10:00 AM
9 minute read
Commentary
On Oct. 5, 2022, a jury found Uber's former security chief, Joseph Sullivan, guilty of felony violations of obstructing a Federal Trade Commission investigation and "misprision of felony" for failing to disclose a 2016 data breach. The case marks the first criminal conviction of a senior executive for obstructing a regulatory investigation into a company's cybersecurity compliance program and concealing a cyber incident from regulators. The conviction comes at a time when federal and state governments are adopting more aggressive policies focused on corporate enforcement and cybersecurity.
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