New York’s chief law enforcement agency recently squandered an opportunity to bring much needed guidance to the digital assets space. On October 18, 2021, the Office of New York Attorney General, Letitia James (“NYAG”),...more
11/30/2021
/ Cryptocurrency ,
Cybersecurity ,
Digital Assets ,
Enforcement Actions ,
New York ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
State and Local Government ,
Trading Platforms ,
Unregistered Securities ,
Virtual Currency
The Securities and Exchange Commission (“SEC”) and Financial Industry Regulatory Authority (“FINRA”) recently issued guidance in connection with firms’ relationships with third-party service providers. These publications...more
2/28/2020
/ Alternative Trading System (ATS) ,
Broker-Dealer ,
Cybersecurity ,
Examination Priorities ,
Financial Industry Regulatory Authority (FINRA) ,
Market Access Rule ,
Market Participants ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Service Provider ,
Vendors
To gain insight into where the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) have been focusing their oversight and what their priorities will be in 2020, look no further than...more
10/31/2019
/ Anti-Corruption ,
CFTC ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement Actions ,
Government Investigations ,
Market Abuse ,
Popular ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Strategic Enforcement Plan
On April 29, 2019, just months into her new job at the New York State Department of Financial Services (“DFS”), acting DFS Superintendent Linda Lacewell announced a significant reorganization within the financial and...more
Earlier this month, the Securities and Exchange Commission (“SEC”) took a break from its recent focus on digital assets and the Best Interest fiduciary standard to publish a Risk Alert encouraging investment advisers and...more
4/30/2019
/ Broker-Dealer ,
Customer Information ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Opt-Outs ,
Policies and Procedures ,
Privacy Policy ,
Regulation S-P ,
Regulatory Requirements ,
Risk Alert ,
Securities and Exchange Commission (SEC)
In late December, New York State’s Department of Financial Services (“DFS”) released its revised proposed cybersecurity regulation (the “DFS Rule”). While the revisions pare back some of the DFS Rule’s original requirements...more
2/1/2017
/ Banks ,
Covered Entities ,
Cybersecurity ,
Department of Financial Services ,
Employee Training ,
Encryption ,
Federal Bank Regulatory Agencies ,
Final Rules ,
Financial Institutions ,
GLBA Privacy ,
Gramm-Leach-Blilely Act ,
Insurance Industry ,
NIST ,
Popular ,
Risk Assessment ,
Third-Party Service Provider
If the New York State Department of Financial Services (“DFS”) has its way, come January 1, 2017, financial services companies that require a form of authorization to operate under the banking, insurance, or financial...more
9/23/2016
/ Banks ,
Breach Notification Rule ,
Chief Information Security Officer (CISO) ,
Covered Entities ,
Cybersecurity ,
Department of Financial Services ,
Financial Institutions ,
Financial Services Industry ,
Information Security ,
Notice and Comment ,
Proposed Regulation
The Security and Exchange Commission’s (“SEC”) recent $1 million settlement with Morgan Stanley Smith Barney LLC (“MSSB”) marked a turning point in the agency’s focus on cybersecurity issues, an area that the agency has...more
7/2/2016
/ Broker-Dealer ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Customer Funds Protection ,
Cybersecurity ,
Data Breach ,
Enforcement Actions ,
Investment Adviser ,
Misappropriation ,
Morgan Stanley ,
Personally Identifiable Information ,
Regulation S-P ,
Securities and Exchange Commission (SEC) ,
Settlement