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Draft NIST Guidance Highlights Supply Chain Fundamentals as Key Practices in Cyber Supply Chain Risk Management

Client Alert | 1 min read | 02.21.20

Last week, the National Institute of Standards and Technology (NIST) published the draft NISTIR 8276 “Key Practices in Cyber Supply Chain Risk Management” providing Key Practices and related recommendations for monitoring, controlling, and understanding how to conduct cyber – supply chain risk management (C-SCRM). The Eight Key Practices are general and apply equally, in practice, to both traditional supply chain management and C-SCRM, including:

  • Integrating SCRM across the organization,
  • Understanding the organization’s supply chain, and
  • Assessing and monitoring SCRM throughout the supplier relationship. 

Specific guidance includes, among others:

  • Increasing Board involvement in C-SCRM;
  • Understanding the cyber relationship with suppliers, including whether they process critical data; and
  • Using third-party assessments to evaluate suppliers.

The guidance should serve to remind organizations of the need to know their supply chain well and to have a purposeful approach to its management. Organizations have an opportunity to comment on this draft guidance until March 4, 2020.

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....

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