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SEC Continues to Zero in on Importance of Data Security Measures and Reporting With Latest $10 Million Penalty

Last month, the Securities and Exchange Commission (SEC) reemphasized just how serious companies must be about maintaining a vigilant cybersecurity posture and procedures to report cyber incidents in a timely manner....more

Next Steps for Companies Ahead of December Deadline for SEC Cybersecurity Disclosures

In less than three months, public companies and certain foreign private companies will have to take additional steps after cybersecurity breaches: deciding whether an incident meets the materiality threshold that requires...more

Cyberfraud Victims May Have Violated SEC Internal Control Requirements: Adding Insult to Injury

Just when you thought the hazards of cyberfraud couldn’t get worse, the SEC recently issued a Report of Investigation (more on that later) stating that nine recent corporate victims of cyberfraud may have compounded their...more

Don’t Overlook the SEC’s Cybersecurity Governance Guidance

In late February, the SEC approved what it labeled “Guidance on Public Company Cybersecurity Disclosures.” And, sure enough, about three-quarters of its 24 pages focus on the various categories and locations of cybersecurity...more

The FTC’s New Data Breach Response Guide (and a Reminder)

The two-pronged mission of the Federal Trade Commission is to protect consumers and promote competition. According to the FTC’s website, protecting consumers includes “stopping unfair, deceptive or fraudulent practices in the...more

Cybersecurity at Small and Midsize Businesses

Cyberattacks against the country’s largest companies tend to garner the most press coverage and generate the most cybersecurity anxiety. For example, such high profile companies as eBay, JP Morgan, Home Depot and Target are...more

Addressing Cybersecurity in Board Committee Charters

As boards of directors have become more focused on their fiduciary duties to oversee cybersecurity, new governance practices have begun to develop. For example, many companies have shifted cybersecurity oversight from the...more

The DOJ’s Cyber Incident “Best Practices” Guidance

The Cybersecurity Unit of the U.S. Department of Justice released in April its “Best Practices for Victim Response and Reporting of Cyber Incidents,” which it says reflects “lessons learned by federal prosecutors while...more

Two Oft-Neglected Cybersecurity Protections

With each passing year, cybercrime moves further into the mainstream of public company existence. What until recently was mostly an annoying, abstract concern for a handful of companies is now a daily menace that impacts...more

Data Breach Preparedness Continues to Lag

A recent study by an independent research institute suggests that the increase in companies’ efforts to prepare for data breaches may not be keeping up with the increased risk. A September 2014 report by Ponemon Institute LLC...more

Cybersecurity Disclosure Heats Up

Due to the current proliferation of technology and electronic connectivity among various aspects of nearly every company’s business, cybersecurity risks continue to grow exponentially. However, the disclosure related to those...more

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