News & Analysis as of

Cybersecurity: Having a Privacy Policy is Not Enough

With the rash of significant data security incidents that occurred in 2013 and have continued to this day, it is increasingly important for companies to have an updated cybersecurity preparedness plan. The World Economic...more

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

And On The 12th Day Of Privacy, Something For Directors…..Mind The Gap!

On our last “day of Privacy”, we have a little extra (perhaps a lump of coal….) post: in 2014, cyber risk has been elevated to a board issue – read on and forward to your favorite company director! As we have discussed...more

How’s Your BCP?

Last week, staff at the SEC, CFTC, and FINRA drew some lessons from Hurricane Sandy and warned broker-dealers and other firms to take steps to prepare themselves for natural disasters that could disrupt their operations....more

SEC Adopts Changes to Broker-Dealer Net Capital and Financial Responsibility Rules

The US Securities and Exchange Commission recently adopted important changes to the financial responsibility rules for securities broker-dealers, including changes to the regulatory capital and regulatory reporting rules. The...more

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

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