No Breach Too Small: OFSI Reports First Breach of UK’s Russian Sanctions Regulations

On 31 August 2023 the UK’s Office of Financial Sanctions Implementation (OFSI) issued a “Disclosure” against Wise Payments Limited, a UK-registered company, regulated by the Financial Conduct Authority, for breaching Regulation 12 of The Russia (Sanctions) (EU Exit) Regulations 2019 by making funds available to a company owned or controlled by a designated person.

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FTC Releases New Health Breach Notification Rule Guidance, Targets Health Apps and Connected Devices

In a new post on the Covington Digital Health blog, our colleagues discuss recently announced Federal Trade Commission (“FTC”) guidance meant to help companies determine their obligations under the Health Breach Notification Rule (the “Rule”).  The guidance follows the FTC’s September 2021 Policy Statement, which expanded the Rule’s application to the developers of health apps, connected devices, and similar products, and similarly emphasize the FTC’s continued scrutiny of health technology.  The post walks through the new guidance documents, which, notably, … Read the rest