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2024 SEC Cybersecurity Rule Updates

The first year of a new significant regulatory obligation is often more notable for the absence of regulatory enforcement actions as regulators often observe compliance efforts and challenges, offer guidance, and look for...more

The SEC’s Regulation of Cybersecurity Continues

The Securities and Exchange Commission entered into a resolution agreement with R.R. Donnelley & Sons (RRD) on June 18, 2024 with RRD agreeing to pay $2.125 million to resolve disclosure and control violations alleged by the...more

Addressing the SEC’s New Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure Requirements

In July 2023, the SEC adopted new cybersecurity rules for the stated purpose of enhancing and standardizing disclosures regarding cybersecurity risk management, strategy, governance and incidents by public companies. The...more

SEC Proposes Rules on Disclosure of Material Cyber Incidents and Cybersecurity Practices for Public Companies

On March 9, 2022, the SEC released proposed rules intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and cyber incident reporting by companies that are subject to the...more

The Scourge of Ransomware

Our 2021 Data Security Incident Response Report (DSIR) described ransomware as a scourge. There are stories every day about new threat actor groups and their victims. There are task forces, law enforcement initiatives,...more

Do You Need a Chief Digital Risk Officer (or Digital Risk Working Group)?

Axioms are common in the privacy and security space. One that has been popping up with more frequency is “privacy and security is an enterprise risk that requires an enterprise-wide effort to appropriately address.” It is...more

Proposed FFIEC Guidance on Financial Institution Social Media Use

The Federal Financial Institutions Examination Council (FFIEC) released for comment on January 17 its proposed Social Media: Consumer Compliance Risk Management Guidance. There is a 60-day comment period. The purpose of the...more

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