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New York DFS Targets Third-Party Relationships in Letters to Banks

Why it matters - Continuing the regulatory focus on third-party relationships, New York’s Department of Financial Services (DFS) has sent multiple letters to banks across the country to address the issue of data...more

Deputy Treasury Secretary Discusses Cybersecurity Checklist for Banks

Deputy Treasury Secretary Sarah Raskin, who recently spoke at the Texas Bankers’ Association Executive Leadership Cybersecurity Conference, provided bank executives and boards some guidance on preventing, preparing for and...more

New York Establishes New Cyber Security Examination Process for Financial Institutions

New York’s Department of Financial Services released a letter on December 10, 2014, announcing the details of its plan to focus more attention on cyber security matters in conducting examinations. Directed at New...more

A Primer on EMV Technology for Merchants

With the new year just around the corner, retailers should make a resolution to learn more about EMV technology. That’s because 2015 is slated to be the year EMV technology makes significant inroads in the United States, and...more

SEC Sanctions Operator of Unregistered Virtual Currency Exchanges

On December 8, the Securities and Exchange Commission sanctioned a computer programmer for operating two online exchanges that traded securities using virtual currencies without registering them as broker-dealers or stock...more

SEC Settles with Bitcoin/Litecoin Exchange Operator

The SEC recently announced a settlement in connection with the operation of unregistered virtual-currency-based stock exchanges. The settlement is instructive as to how the SEC will evaluate crypto-currency trading platforms...more

Treasury Official Urges Banks to Consider Cyber Insurance, Assess Cybersecurity Readiness

On December 3, Deputy Secretary Raskin delivered remarks at the Texas Bankers’ Association Executive Leadership Cybersecurity Conference. During her prepared remarks, Raskin noted recent data security breaches across many...more

The Treasury Recommends Cyberinsurance For Banks

If you think you are being overly paranoid about the recent cyber attacks on Sony, JP Morgan, and Target, think again. You aren’t the only one that has been paying attention – hackers are also front-and-center on the minds...more

Cybersecurity Continues as a Major Focus of Financial Industry’s Concerns

With only three official days left of the current Congress, conversations Wednesday turned towards cybersecurity in the financial sector. The Commodity Futures Trading Commission, Office of the Comptroller of the Currency,...more

SEC Issues Revisions to Regulation AB Telephone Interpretations

On December 9, the SEC issued Compliance and Disclosure Interpretations (“C&DIs”) that comprise the SEC’s interpretations of the rules adopted under Regulation AB II and the Securities Act and the Exchange Act. The new C&DIs...more

Sophisticated Hackers Target Insider Information

A security consulting firm has discovered a sophisticated hacking campaign that has targeted more than 100 public companies, investment banks and law firms. In a report released December 1, cybersecurity firm FireEye...more

Financial System Inquiry - Final Report Summary of Recommendations re Innovation

On 7 December 2014 the Final Report was issued by the Financial System Inquiry, chaired by David Murray. Below is a summary of the key points relevant only to innovation. This update does not seek to address matters in the...more

NYS DFS Publishes All BitLicense Comments; California Considers Regulation

On December 3, the New York State Department of Financial Services (DFS) published all 3,746 public comments it received on the proposed “BitLicense” regulatory framework that would cover businesses participating in “virtual...more

Court Allows Financial Institutions To Proceed With Data Breach Class Action Against Target

On December 2, 2014, a U.S. District Court in Minnesota ruled that a group of banks and other financial institutions (collectively, “FIs”) could proceed with a class action against large national retailer Target arising from...more

Minnesota Federal Judge Allows Data Breach Suit Against Target to Proceed

On December 2, District Judge Paul Magnuson denied Target’s motion to dismiss the class action suit brought by banks in response to its 2013 data breach. In re: Target Corporation Customer Data Security Breach Litigation,...more

Trade Associations Submit Letter to Congress regarding Cybersecurity Information Sharing

On December 3, the Merchant and Financial Associations Cybersecurity Partnership (“Partnership”) submitted a letter to Congress requesting its consideration of adopting cybersecurity information sharing legislation. ...more

An Early Christmas Present for Consumers? Court Rules that Retailers Can Be Liable to Banks Arising from Data Breaches.

Cyber-Monday sales weren’t the only good thing that happened for consumers last week. Later in the week a federal judge in Minnesota thwarted Target’s attempt to dismiss a lawsuit brought by banks and credit unions arising...more

FinCrimes Update - November 2014 Summary, Volume 1, Issue 9

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. ...more

Ruling Gives New Life to Bank Claims Against Breached Retailers in Target Case

One common occurrence after the disclosure by a retailer of a breach affecting card present payment card data used to be the filing of claims by banks that issued payment cards affected by the incident. The banks bringing the...more

Cyber Monday – December 1, 2014

Welcome to December – we hope you had a restful and enjoyable Thanksgiving holiday. Here are a few privacy bits and bytes to start your week. 1. ICYMI – 60 Minutes Explains Credit Card Hacking...more

Advanced technological service enterprises continue to enjoy preferential income tax treatment

The Ministry of Finance and the State Administration of Taxation jointly issued the Circular, on Issues regarding Improving Enterprise Income Tax Policies ("EIT") for Technologically Advanced Service Enterprise ("ATSE")...more

CRA Announces Collaboration with CPA Canada

As expected, the CRA has formally announced the details of its collaborative efforts with CPA Canada. The CRA recently spoke about this collaboration at the Toronto Centre CRA-Tax Professionals breakfast seminar....more

SEC Adopts Regulation Systems Compliance and Integrity Rules

On November 19, the Securities and Exchange Commission adopted new Regulation Systems Compliance and Integrity (Regulation SCI), a set of rules designed to strengthen the technology infrastructure of the US securities markets...more

Privacy Tuesday - November 2014 #2

Here are three privacy stories to start your week - 1. Dear “financial institution” : how is your data security?! Senator Elizabeth Warren (D-Mass) announced (press release) that on November 18 the Senator...more

Digital Currency Corner - What FinCEN’s Denial of Payment Processing Exemption for Virtual Currency-Related Businesses Means for...

Why it matters - The rapid evolution of virtual and digital currencies has spawned significant activity in several federal agencies with implications potentially for traditional entities in certain cases. In addition...more

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