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Examination Priorities for 2017 from FINRA and OCIE

In these uncertain times, the predictability and regularity of the annual priorities letters from FINRA and the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) is...more

New York Finalizes Cybersecurity Regulations for Financial Institutions

On February 16, the New York State Department of Financial Services (NYDFS) issued cybersecurity regulations for banks, insurance companies and other financial institutions subject to NYDFS jurisdiction. ...more

Brussels Regulatory Brief: February

On 1 January 2017, the torch of the Presidency of the Council of the European Union (“EU”) was passed from Slovakia to Malta. The Presidency rotates every six months between the EU Member States, but continuity is guaranteed...more

Dentons Rodyk Reporter 2017

Regional CEO message - Happy New Year and welcome to the first issue of Dentons Rodyk Reporter 2017. Let me share our key developments in 2016 and tell you what to expect from us in 2017. Please see full...more

NYDFS: A Lawyer’s Responsibility

New York Financial Regulator to Enforce First-of-Its-Kind Cybersecurity Regulations in Coming Weeks - On December 28, 2016, the New York Department of Financial Services (NYDFS) issued revised cybersecurity regulations...more

FINRA Fines Lincoln Financial Sub $650,000 For Cybersecurity Shortcomings

A Lincoln Financial Group subsidiary agreed to pay $650,000 to the Financial Industry Regulatory Authority (FINRA) to resolve allegations that it failed to implement sufficient security policies to protect confidential...more

DFS Cyber Regulation: Part II – An Interview with Bay Dynamics’ Steven Grossman

This is the second installment in our interview with Steven Grossman, VP Strategy & Enablement at Bay Dynamics, the cyber risk analytics company. Here, Steven discusses the importance of aligning an institution’s risk...more

Cyber Regulation Demands Board Accountability: Part 2 in a 3-Part Series

This is our second installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation. In this installment, we provide an overview of the regulation’s impact...more

Accountants M&A Alert: New AICPA Guidance on Transfer of Client Files

If you are selling or acquiring an accounting practice, you need to read the AICPA’s new guidance “Transfer of Files and Return of Client Records in Sale, Transfer, Discontinuance or Acquisition of a Practice,” which...more

FFIEC Releases Answers To FAQs About Cybersecurity Assessment Tool

On October 17, 2016, the Federal Financial Institutions Examination Council (“FFIEC” or the “Council”) released a set of answers to frequently asked questions about its cybersecurity assessment tool (the “CAT”). The FFIEC, an...more

Cyber in the Board Room: Balancing Risk and Oversight

Boards of directors remain increasingly exposed to the threat of liability arising from data breaches and other cyber-incidents. Nearly a year ago, Senators Jack Reed and Susan Collins introduced the Cybersecurity...more

Bitcoin: Cybersecurity Regulations on the Horizon?

As legislators grapple with creating legislation intended to bring virtual currencies, such as bitcoin, within the scope of anti-money laundering regulations, the vulnerability of Bitcoin exchanges to theft and other cyber...more

Guidelines for Written Information Security Policies

Although federal law only requires that financial institutions and health care providers maintain a written information security policy or “WISP,” approximately thirty four states have enacted legislation that requires...more

In Case You Missed It: Launch Links - September, 2016 #4

Some interesting links we found across the web this week: The Hacking Law That Can’t Hack It - For 30 years and counting, courts have struggled with the vagaries of the Computer Fraud and Abuse Act, a federal law...more

Privacy and Cybersecurity Checklist When Designing a Family Office

As family office executives set up a family office or review an existing family office, it is important to make sure the privacy and cybersecurity concerns are addressed and the governance and information security...more

New York proposes cybersecurity regulation aiming to protect financial services companies from criminal enterprises

The New York State Department of Financial Services (NYDFS) has set forth a proposed cybersecurity regulation for financial service companies. Announced this week by New York  Governor Andrew M. Cuomo, the proposed rule seeks...more

Spoofing, Sports and the Panama Papers: BakerHostetler Offers Mid-Year Review of Cross-Border Government Investigations and...

Halfway through 2016, the international community has seen a staggering variety of cross-border investigations and enforcement actions. Brexit, the release of the Panama Papers, allegations of widespread sports doping and the...more

Asset Protection Wake Up Call: Data Security Top Concern for High Net Worth Investors

A recent study asked high net worth investors which of the following issues they were most concerned about: terrorism, data security, or a major illness. The most prevalent response might surprise you. Seventy-two percent...more

It's All About Blockchain - Don't Miss These 7 Reads

Don't miss these seven popular reads on Blockchain....more

UK Financial Conduct Authority—Regulated Firms Can Go to the Cloud

July 7, 2016, saw the UK’s Financial Conduct Authority (FCA) publish fresh guidance in order to clarify the requirements which apply to the financial services firms it regulates when outsourcing to the cloud. When the FCA...more

Are You an Insider? Data Privacy Challenges Posed by New Insider List Requirements

The EU’s Market Abuse Regulation (“MAR”) came into effect on July 3, 2016 replacing the EU’s Market Abuse Directive. Unlike the Directive, the MAR has direct effect in each EU member state, including the UK....more

The SEC Now Has A Lead Cybersecurity Senior Adviser: Now What?

The SEC recently created a new position associated with cybersecurity; senior adviser to the chair for cybersecurity (Christopher R. Hetner). Mr. Hetner has an extensive background in information technology and, in...more

Blog: FCA publishes guidance for firms outsourcing to the cloud and 3rd-party IT service providers

The FCA has published its final “guidance for firms outsourcing to the cloud and other 3rd-party IT services“. The guidance is generic in two senses: it “aims to help firms and service providers understand [the FCA’s]...more

Brexit – What Now For Your Business

So, the UK has voted to leave the EU. Everyone has their own opinion and we’ve all seen the news reports and various viewpoints but what does this result mean for you in practical terms and where do we go from here? Orrick’s...more

Brexit: What to Expect and How to Prepare for the ‘New Normal'

The U.K. has voted, in a popular referendum, to leave the EU. The referendum is not legally binding and the result was extremely narrow: 51.9 percent in favor of leaving, 48.1 percent in favor of remaining. This partly...more

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