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SEC Adopts Final Cybersecurity Disclosure Rules

On July 26, 2023, the U.S. Securities and Exchange Commission (the “Commission”) adopted final rules on cybersecurity risk management, strategy, governance, and incident disclosure by a split vote of 3-2. While the...more

New York Department of Financial Services Proposes New Cybersecurity Rules

On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Part 500 Cybersecurity Rules, which propose substantial new obligations for the cybersecurity programs of companies...more

SEC Proposes Rules Enhancing Cybersecurity Disclosures

On March 9, 2022, the Securities and Exchange Commission (SEC) proposed rules intended to enhance and standardize public company disclosures regarding cybersecurity risk management, strategy, governance, and incident...more

SEC Returns Spotlight to Cybersecurity Disclosure Enforcement

On June 15, the Securities and Exchange Commission announced a settlement with First American Financial Corporation for what the SEC found were inadequate disclosure controls and procedural violations, revealed in connection...more

NY DFS Cybersecurity Regulation in the Face of COVID-19

The New York Department of Financial Services’ (DFS) cybersecurity regulation imposes significant requirements on financial services companies doing business in New York. DFS, which enforces the regulation, has remained...more

Broad Consumer Privacy Bill Introduced In New York State Senate

New York’s State Senate is considering a bill that would impose sweeping new requirements upon companies that collect and process consumer data, including a fiduciary-like duty to protect such data. On May 9, 2019, New York...more

NY DFS Cybersecurity Regulation, Two Years In - What Comes Next?

This past Friday, March 1, 2019, marked the second anniversary and final effective date of the New York Department of Financial Services (DFS)’s cybersecurity regulation. Since its enactment, regulated institutions, subject...more

A Peek Behind the Curtain at the Largest Crypto Trading Platforms

New York Attorney General’s Office publishes a detailed report on policies and practices at virtual asset trading platforms, citing multiple common deficiencies - The New York Attorney General’s Office (“NYAG”) issued a...more

FinTech Fraternization: CFTC and NFA Announce Cross-Border Collaboration Agreement

Nearly a year after then-acting US Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo actively promoted FinTech innovation as a key to economic growth, he has minted a groundbreaking FinTech...more

Financial Industry Regulatory Priorities In 2018 FINRA and OCIE Announce Examination Areas of Focus

In early 2018 both the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) and FINRA announced their examination priorities for 2018. As in previous years, both OCIE and FINRA share many examination priorities...more

New CFTC Director of Enforcement Incentivizes Self-Reporting, Counts on “Buy-in” From Market Participants

In prepared remarks at New York University’s School of Law on September 25, 2017, the newly minted Director of Enforcement at the U.S. Commodity Futures Trading Commission passionately outlined the contours of the CFTC’s new...more

A Constitutional Check on Cross-Border Enforcement Tactics: Takeaways from the Second Circuit’s Decision in United States v. Allen

Today’s global investigations frequently involve the cooperation of many government agencies in multiple countries. On July 18, 2017, the U.S. Court of Appeals for the Second Circuit handed down a decision creating a major...more

The FX Global Code - The Rules are Made to be Followed

The foreign exchange industry (“forex” or “FX”), a seemingly ever-growing massive liquid market accessible to many kinds of market participants, has finally started showing signs of a slowdown. In 2016, the world’s largest...more

FinTech – The CFTC’s Silver Bullet?

On March 15, Acting US Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo excited the futures and options markets when he spoke at length about embracing technology as a key to economic growth. ...more

4/13/2017  /  CFTC , FinTech , Popular , Technology Sector

2017 Financial Industry Regulatory Priorities - OCIE and FINRA Announce Examination Areas of Focus

In early January, both the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) and FINRA announced their examination priorities for 2017. As in previous years, both the SEC and FINRA share many examination...more

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