Author Archives: ab12757

T-Mobile to Spend 31.5 Million Dollars to Settle Multiple FCC Investigations Related to Recent Data Breaches

by Lisa Sotto and Jennie Cunningham

Photos of the speakers

Left to right: Lisa Sotto and Jennie Cunningham. (Photos courtesy of Hunton Andrews Kurth LLP)

On September 30, 2024, the Federal Communications Commission announced that T-Mobile has entered into an agreement to settle multiple data protection and cybersecurity investigations stemming from data breaches in 2021, 2022 and 2023. The breaches involved the personal information of millions of current, former, and prospective T-Mobile customers and end-user customers of T-Mobile wireless network operators, and resulted from various threat vectors, including a 2021 cyberattack, a 2022 platform access incident, a 2023 sales application incident, and a 2023 API incident. T-Mobile previously settled class action claims in federal district court related to the 2021 cyberattack. In addition to a $15.75 million penalty, T-Mobile also will be required to spend $15.75 million over the next two years to strengthen its cybersecurity program and implement a plan to protect consumers from similar future breaches. Continue reading →

Three – No, Four – Important Revisions to the Department’s Policy on the Evaluation of Corporate Compliance Efforts

by Bethany Hengsbach and Steve Solow

From left to right: Bethany Hengsbach, and Steve Solow. Photos courtesy of the authors.

In a speech at the Program on Corporate Compliance and Enforcement at NYU School of Law, Nicole Argentieri, Acting Assistant Attorney General of the Criminal Division, announced key revisions to the March 2023 Evaluation of Corporate Compliance Programs (ECCP). The September 17, 2024 speech was followed by the release of the updated ECCP on the DOJ website. The revised ECCP converts leading edge compliance efforts into standard operating procedures (SOPs) against which companies will be judged by the Department of Justice (DOJ) when making prosecution decisions. The primary changes include three new areas of focus, and a fourth important expansion of a pre-existing idea: Continue reading →