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FDIC Reissues Technology Outsourcing Resources, Urges Use Of Cyber Resources

On April 7, the FDIC reissued, as attachments to FIL-13-2014, three technology outsourcing resources. The documents, which the FDIC describes as containing “practical ideas for banks to consider when they engage in technology...more

SEC’s OCIE Announces Cybersecurity Examinations Of Broker-Dealers And Registered Investment Advisers

The SEC’s Office of Compliance Inspections and Examinations, or OCIE, previously announced that its 2014 Examination Priorities included a focus on technology, including cybersecurity preparedness. OCIE has issued a Risk...more

Aggressive Liability Theory Does Not Eliminate Obstacles To Banks’ Claims In Target Data Breach Class Action

The latest salvo in the Target data breach litigation is a class action brought by credit card issuing banks advancing a creative and somewhat misleading construction of the Minnesota’s Plastic Card Security Act. The banks...more

FFIEC Advises Banks On Website, ATM Cyber Attacks

On April 2, the FFIEC advised financial institutions that distributed denial-of-service (DDoS) attacks on a financial institution’s public websites present operational and reputation risks. If coupled with attempted fraud, a...more

FTC Announces Settlements with Data Brokers over Alleged FCRA Violations

The Federal Trade Commission recently announced two more settlements with data brokers for alleged violations of the Fair Credit Reporting Act (FCRA). The settlements with Instant Checkmate, Inc., InfoTrack Information...more

FFIEC Issues Joint Statements on DDoS Cyber-Attacks and Cyber-Attacks on ATM and Card Authorization Systems

On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more

The SEC Cybersecurity Roundtable: Indicator of Things to Come?

Starting with the Securities and Exchange Commission's January 2014 announcement that cybersecurity is a priority in its National Examination Program, SEC Chair Mary Jo White and others at the SEC have continued to stress the...more

SEC Holds Cybersecurity Roundtable

On Wednesday, March 26, 2014, the Securities and Exchange Commission conducted a roundtable discussion on cybersecurity and the issues and challenges cyber-threats present for public companies, exchanges, and market...more

Cybercrime Loses Its Right to Silence

In 2012, the director gen¬eral of MI5 revealed that a London-listed company had lost £800 million as a result of a state-backed cyber at¬tack. The company in question has not been publicly identified and no disclosures were...more

Closing The Gap Between Privacy Policies And The Use Of Portable Storage Devices

The Office of the Privacy Commissioner of Canada has released its Report of Findings from a year-long investigation into a significant incident involving the loss of personal data at the former Ministry of Human Resources and...more

Visa, MasterCard Announce Payment Security Working Group

On March 7, Visa and Mastercard announced the formation of a cross-industry payment security working group, which the payment system providers state will be focused on “enhancing payment system security to keep pace with the...more

Moving Towards a Global Harmonized Approach to Cross-Border Data Transfers?

Today, data can be transferred around the world instantaneously, making the global marketplace seem almost borderless. As any multinational company knows, however, compliance with each country’s data transfer and privacy laws...more

Comptroller Curry Comments On Outsourcing Risks

On March 4, Comptroller of the Currency Thomas Curry addressed the annual meeting of the Independent Community Bankers Association where he stressed the need for banks to effectively manage risk presented by the outsourcing...more

New Report on PCI-DSS Compliance Finds Room for Improvement

Data breaches are increasingly common, with an estimated $11 billion in global credit-card fraud in 2012 alone. Yet according to a new report, many organizations still fail to take the necessary security measures to prevent...more

Bitcoin Exchange Mt. Gox Files for Bankruptcy Protection; May Have Broader Implications for Digital Currency Industry

On February 28, 2014, international Bitcoin exchange Mt. Gox filed for bankruptcy protection in Tokyo, capping what is likely the most tumultuous month yet in the history of the controversial virtual currency. Mt. Gox—the...more

Privacy & Cybersecurity Update - February 2014

In This Issue: - NIST Releases Final Framework Document ..Key Changes From The Preliminary Framework ..The Framework Roadmap ..The DHS “C-Cubed” Program ..Next Steps - California Suggests Upper...more

Attorney General Holder Calls on Congress to Establish Strong National Data Breach Notification Standard

Yesterday, in his weekly video address, Attorney General Eric Holder urged Congress to create a national data breach notification standard requiring companies to quickly notify consumers of a breach of their personal or...more

Cyber-Security in Corporate Finance

The ICAEW has partnered with a task force, including the Law Society, the London Stock Exchange, the Takeover Panel and the Confederation of British Industry, to publish a guide on ‘Cyber-Security in Corporate Finance’ for...more

National Cybersecurity Framework Released - Has Your Organization Considered the Implications?

On February 12, 2014, the National Institute of Standards and Technology ("NIST") released the final version of its Framework for Improving Critical Infrastructure Cybersecurity (the "Cybersecurity Framework" or "Framework")...more

FINRA Conducting Cyber-Security Sweep Exam

Reacting in part to recent data-breaches and cyber-attacks on larger retailers, the Financial Industry Regulatory Authority (“FINRA”) is conducting a targeted examination of some 20 broker-dealer member firms’ compliance and...more

FINRA Announces a Sweep to Assess BDs’ Cybersecurity

After announcing that cybersecurity will be one of its 2014 examination priorities, FINRA wasted no time before commencing a sweep. FINRA announced a Targeted Examination Letter to conduct an assessment of firms’ approaches...more

SEC Examiners to Take a Close Look at Firms’ Cyber Security

A high-level SEC official told an industry group yesterday that the National Examination Program (NEP) will be reviewing asset managers’ policies and procedures for preventing cyber attacks. In particular, the SEC is looking...more

3 Bitcoin Lessons for Designing a Private and Secure Payment System

Although reasonable people may disagree about whether Bitcoin is that ideal payment system, Bitcoin is worth studying for its privacy and security lessons and its potential to emerge as an important additional payment system....more

Privacy and Information Security Alert

The final Federal Cybersecurity Framework is imminent. Find out how the Framework operates and how it may impact your business. Learn what government and industry leaders say about the Framework and the need for related...more

New Personal Data Protection Law

On 21 May 2013, the Parliament of the Republic of Kazakhstan adopted the Law “On Personal Data” (the “Personal Data Law”), which entered into force on 25 November 2013. The Personal Data Law affects all commercial and...more

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