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In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more
US financial services regulators are continuing to enhance cyber reporting requirements in response to increasing geopolitical tensions, emerging technologies, the proliferation of cyber-attacks, and larger market events....more
SEC Division of Examinations Issues Risk Alert on Regulation S-ID and Identity Theft Prevention Programs - On December 5, 2022, the Securities and Exchange Commission (“SEC”) Division of Examinations (“EXAMS”) issued a...more
This past summer’s string of cyber enforcement actions signals that cybersecurity has become a top priority for the US Securities and Exchange Commission (“SEC”). This focus is consistent with the SEC’s Division of...more
The U.S. Securities and Exchange Commission (“SEC”) recently identified cyberthreats as an enforcement priority (see 2021 Examination Priorities). Within months of the Commission’s announcement, the Commission brought three...more
Background - On August 30, 2021, the Securities and Exchange Commission (SEC) sanctioned eight firms in three actions for cybersecurity failures in their policies and procedures that exposed the personal information of...more
There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more
As publicly reported late last week, the Securities and Exchange Commission’s Division of Enforcement (SEC) sent voluntary requests for information to a range of public companies and investment firms seeking voluntary...more
The massive SolarWinds security breach, which affected not only the private sector, but federal, state and local governments, has caused some to question whether to share data with the government. On Friday, December 18, the...more
On September 15, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a cybersecurity risk alert highlighting the increased use of “credential stuffing” attacks against investment advisers and...more
The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) has published a risk alert, warning SEC-registered investment advisers, brokers and dealers about the increasing use of...more
The Risk Alert makes clear that OCIE has observed an increase in the frequency of credential stuffing attacks against Registrants, including some successful credential stuffing attacks that resulted in the loss of customer...more
On September 15, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert highlighting the recent uptick in “credential stuffing” cyber-attacks against SEC-registered investment advisors...more
The coronavirus crisis is far from over, and compliance professionals still need every scrap of guidance that regulators can provide about how to run compliance programs in these difficult times. So when the Securities and...more
The SEC's Office of Compliance and Examinations (OCIE) issued a risk alert on July 10th about its observation of an apparent increase in sophistication of ransomware attacks on SEC registrants, including broker-dealers,...more
- In the age of broad corporate teleworking brought on by COVID-19, OCIE of the SEC has observed during recent examinations that investment advisers, broker-dealers and investment companies are subject to an increased threat...more
On December 20, 2018, the Financial Industry Regulatory Authority (FINRA) issued a “Report on Selected Cybersecurity Practices” (the “Report”) as part of its ongoing efforts to assist broker-dealer firms in developing...more
The U.S. Securities and Exchange Commission (SEC) recently announced a consent order settling an enforcement action brought by the SEC against Voya Financial Advisors Inc. (VFA) in connection with a data security incident...more
UNITED STATES - Regulatory—Policy, Best Practices, and Standards - FTC Comments on Improvements to IoT Device Security - On June 19, the Federal Trade Commission ("FTC") submitted comments to a working group organized by the...more
On May 17, 2017, the SEC’s Office of Compliance Inspection and Examination (“OCIE”) issued a risk alert urging broker-dealers, investment advisors and investment companies to safeguard themselves against ransomware in light...more
The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a National Exam Program Risk Alert (Risk Alert) on May 17, 2017 in response to “WannaCry,” the ongoing...more
The U.S. Securities and Exchange Commission's Office of Compliance Inspections and Examinations (OCIE) has issued a Risk Alert in the wake of the widespread WannaCry ransomware attack that has inflicted hundreds of thousands...more
The U.S. Securities and Exchange Commission is asking broker-dealers, investment advisers and funds to redouble their cybersecurity efforts in wake of the global cyber-attack of the WannaCry virus that has spread to more than...more
On October 25, the Financial Crimes Enforcement Network (FinCEN), one of the U.S. Department of the Treasury’s lead agencies in the fight against money laundering, issued an Advisory to Financial Institutions on Cyber-Events...more
Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more