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
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
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
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
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
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
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
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
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
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
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
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
7/26/2017
/ Appeals ,
Compelled Testimony ,
Corporate Counsel ,
Criminal Convictions ,
Cross-Border ,
Enforcement Actions ,
Fifth Amendment ,
Financial Conduct Authority (FCA) ,
Foreign Jurisdictions ,
Indictments ,
Libor ,
Rabobank ,
UK
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
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
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