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The FAR Regulators Enter the Cyber Fray

Client Alert | 1 min read | 08.28.12

On the heels of the latest demise of cyber legislation, the FAR Council has proposed new cybersecurity regulations for safeguarding government information ("other than public information") residing on or transiting through contractors' systems. While lacking some of the detail (such as certain NIST standards) contained in a predecessor proposal by DOD, the proposed FAR rule establishes broad requirements for basic cybersecurity safeguards for "all Federal contractors and appropriate subcontractors," including mandates for  (1) "the best level of security and privacy available, given facilities, conditions, and environment"; (2) "at least one physical and one electronic barrier" for such information; (3) "sanitization" prior to disposal of information and electronic media; and (4) "intrusion protection," such as "updated malware protection services."

Insights

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....