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Risk Assessment

Avoiding Management Struggles When it Comes to Data Breaches: Part 6

by Bryan Cave on

The best way for a company to handle a data breach is to be prepared. As we discuss in our data breach readiness handbook, preparation includes, among other things, drafting an incident response plan, reviewing...more

Recent Events Increase the Importance of HIPAA Risk Analyses and HIPAA Policies

Recent events highlight the fact that threats to customer and patient data continue to increase. In recent months, government agencies, news outlets, and others have spent considerable time investigating and reporting on...more

The Good and the Bad from OCIE’s Cyber Examinations and What Firms Should Do Next

by Dechert LLP on

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a National Examination Program Risk Alert (Risk Alert) on August 7, 2017 regarding observations from...more

New York State Cybersecurity Regulations: First milestone in sight, what is next on the horizon?

by Shearman & Sterling LLP on

The New York State Department of Financial Services (“NYDFS”) enacted final cybersecurity regulations (“Regulations”) for NYDFS regulated entities that went into effect on March 1, 2017. The first deadline for compliance...more

Developments in New York and Colorado Cybersecurity Regulations

by Wilson Elser on

New York - For the first time since New York’s Cybersecurity Regulation (23 NYCRR Part 500) became effective on March 1, 2017, the Department of Financial Services (DFS) has issued Frequently Asked Questions to assist...more

Deadline to Comply with New York's Cybersecurity Regulation Is Approaching

by Jones Day on

For entities regulated by the New York Department of Financial Services, the deadline for complying with the new Cybersecurity Requirements for Financial Services Companies, 23 NYCRR Part 500, is Monday, August 28, 2017. To...more

Day 15 of One Month to More Effective Continuous Improvement-Risk Based Monitoring for Continuous Improvement

by Thomas Fox on

Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested...more

Governors of 38 States Join a Cybersecurity Compact

by Wilson Elser on

On July 16, 2016, the chair of the National Governors Association (NGA), Governor Terry McAuliffe (D-VA), unveiled his 2016-2017 initiative, Meet the Threat: States Confront the Cyber Challenge. Over the past year, the...more

Are You Ready for the New York August 28th Compliance Deadline?  

If you are one of the many businesses licensed by the New York Department of Financial Services (DFS), and cannot avail yourself of the (very) limited exemptions, you must be ready for the first compliance transition date for...more

And So It Begins: The First DFS Transition Period Comes to an End August 28

by King & Spalding on

In September 2016, the New York Department of Financial Services (“DFS”) introduced the first draft of its cybersecurity regulation, which is now in a position to lead a new trend in industry-specific cybersecurity...more

Cybersecurity Insights From The SEC

by Fox Rothschild LLP on

Over the last several months, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has been conducting a “sweep examination” of over 70 broker-dealers and investment advisers to assess their cybersecurity...more

New Cybersecurity Rules for Colorado Investment Advisers and Broker-Dealers

by Snell & Wilmer on

Colorado has adopted new rules that add cybersecurity requirements for certain entities with Colorado securities licenses. The rules are from the regulatory agency the Division of Securities. It licenses securities...more

Increase in Chemical Security Vulnerability Assessments Likely Under New DHS Standards

by Williams Mullen on

The Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure that security measures are in place to reduce the risk of...more

EPA Marks First Anniversary of TSCA Reform With Three Implementing Rules

by Williams Mullen on

On the first anniversary of the Frank R. Launtenberg Chemical Safety for the 21st Century Act (also known as the TSCA Modernization Act of 2015), EPA promulgated three significant rules to implement the Act. The Act stands...more

Avoiding Management Struggles When it Comes to Data Breaches: Part 3

by Bryan Cave on

The best way for a company to handle a data breach is to be prepared. As we discuss in our data breach readiness handbook, preparation includes, among other things, drafting an incident response plan, reviewing...more

Debt Dialogue: July 2017 - Non-consolidation and True Sale Issues for Insurance Company Sponsors — Part Two

Our two-part article on non-con and true sale issues in insurance contexts continues with a deeper dive into the considerations that distinguish these issues from similar remoteness principles in a Bankruptcy Code context. In...more

WSGR Fintech Update - August 2017

Wilson Sonsini Goodrich & Rosati is pleased to present the August 2017 issue of the WSGR Fintech Update. This latest edition features an article on the State of Delaware's amendments to permit Delaware corporations to use...more

Using a Human Rights Lens to Strengthen Your Anti-Corruption Compliance Program

Companies are increasingly expected to manage the human rights impacts of their activities. This expectation is embedded in new legislative requirements, in the requirements of business partners and investors, and in the...more

TSCA Implementation Update: EPA Finalizes Framework Rules and Announces Scope For First Risk Evaluations

TSCA Framework Rules Promulgated - As we outlined last year, the Toxic Substances Control Act (“TSCA”) was recently updated to provide EPA with much broader authority to regulate “existing” chemical substances (i.e., those...more

A Primer on Design Professionals’ Liability in Virginia

by Williams Mullen on

When building a construction project in Virginia, it is essential that you understand the obligations and supporting legal principles for each of the parties involved in the Project. You cannot make an informed judgment of...more

No Rules, Just Be Right? The ABA's New Technology Ethics Opinion

by JD Supra Perspectives on

On the heels of the recent Petya ransomware attack, which infected DLA Piper's IT systems, a superb analysis by Peter Norman of the ABA's Formal Opinion 17-477R on lawyers' ethical responsibilities when using information...more

Private Equity Watch - July 2017

by Ropes & Gray LLP on

With the year half over, it’s still too early to say whether it’s going to be a good one or a difficult one for the private equity market. The July edition of Private Equity Watch provides important perspective on the issues...more

Reflections on My Interview with Hui Chen on Compliance Program Effectiveness

by NAVEX Global on

Hui Chen left her job as in-house compliance counsel for the Justice Department at the end of June, and I had the good fortune to be the first person to interview her post-departure....more

OIG Unveils New Work Plan Process: Assessing the Impact on Compliance Risk Assessment

by Baker Ober Health Law on

On June and July 17, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) released new Work Plan initiatives and, in doing so, announced its intent to update its Work Plan monthly, in lieu of a...more

Chris Froome Wins Tour Again; Maintenance and Compliance

by Thomas Fox on

Just as he did in 2013, in 2015 and in 2016, Kenyan-born British cycling star Chris Froome crossed the finish line in Paris wearing the Yellow Jersey as this year’s winner of the Tour de France. As reported by Chris Chavez,...more

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Cybersecurity

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