On January 29, 2024, the Department of Commerce (“Department”) published a proposed rule (“Proposed Rule”) to require providers and foreign resellers of U.S. Infrastructure-as-a-Service (“IaaS”) products to (i) verify the identity of their foreign customers and (ii) notify the Department when a foreign person transacts with that provider or reseller to train a large artificial intelligence (“AI”) model with potential capabilities that could be used in malicious cyber-enabled activity. The proposed rule also contemplates that the Department may impose special measures to be undertaken by U.S. IaaS providers to deter foreign malicious cyber actors’ use of U.S. IaaS products. The accompanying request for comments has a deadline of April 29, 2024.Continue Reading Department of Commerce Issues Proposed Rule to Regulate Infrastructure-as-a-Service Providers and Resellers
John Webster Leslie
Web Leslie advises clients on a broad range of challenges and opportunities at the intersection of technology and security, including investigations, regulatory, and transactional matters related to cybersecurity, national security, critical infrastructure, and data privacy.
In his white-collar practice, Web helps clients navigate both government and internal investigations. He specializes in complex civil and criminal investigations related to alleged government contracts fraud and other cybersecurity-related allegations under the False Claims Act, FTC Act, and equivalent state laws. Additionally, Web assists clients in responding to a variety of cyber incidents, ranging from intrusions and extortion by advanced persistent threats to business email compromises and large-scale data breaches. Web also helps clients investigate insider threat activity and potential noncompliance with regulatory and contractual cybersecurity requirements.
In his advisory and transactional practice, Web assists clients across a wide range of industries and critical infrastructure sectors manage risk in an evolving regulatory landscape. He regularly advises on cybersecurity compliance and best practices, information security program development, incident response preparedness, insider threat risks, third-party risk management, and international cyber regulations, among other areas. Web also advises clients on a variety of government and industry standards, including the NIST Cybersecurity Framework 2.0, NIST SP 800-53, NIST SP 800-171, FedRAMP and state equivalents (e.g., GovRAMP, TX-RAMP), CJIS, ISO/IEC standards (e.g., ISO 27001), SOC2 Type 2, and other sector-specific requirements (e.g., HIPAA Security Rule, PCI DSS, DFARS Clause 252.204-7012, NERC Critical Infrastructure Protection).
In addition to his regular practice, Web counsels pro bono clients on data breach, immigration, and criminal law matters.
Web previously served in government in different roles at the Department of Homeland Security (DHS), including at the National Protection and Programs Directorate—known today as the Cybersecurity and Infrastructure Security Agency (CISA)—where he specialized in cybersecurity and critical infrastructure protection, public-private partnerships, and interagency cyber operations. He also served as Special Assistant to the Secretary of Homeland Security.