Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets.”  The proposed regulations seek to “require banks and money service businesses (“MSBs”) to submit reports, keep records, and verify the identity of customers in relation

Cybersecurity does not just pose technical challenges; companies must always keep their eye on the human component of cyber risk.  For example, even the most damaging and sophisticated hacks – such as the recent Twitter hacks – can result from spear-phishing. Imagine that: multi-billion-dollar new technology communication apparatuses brought to their knees by charming fraudsters

On May 28, President Donald Trump issued an executive order on preventing online censorship targeting the Communications Decency Act, or CDA, titled “Protection for good Samaritan blocking and screening of offensive material.”[1]

While there remain serious doubts as to the legality of the order, including the extent to which it is a constitutionally impermissible