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SEC and FinCEN Propose Customer Identification Rule for Registered Investment

The Securities Exchange Commission (SEC) and the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued a proposed rule on May 13, 2024 (Proposed Rule), which could have sweeping effects on the...more

Top Privacy and Cybersecurity Issues to Track In 2024

In recognition of International Privacy Day on January 28, we wanted to share some insights on the top privacy and cybersecurity issues for the new year. Data privacy and cybersecurity will continue to be one of the most...more

Faking It: Protecting Your Financial Institution Against Deepfakes

Fraudulent activity in the financial industry is nothing new. The techniques employed by fraudsters have ranged from fake check fraud and credit card fraud to identity theft and financial account takeovers. For years,...more

MOVEit Transfer Zero-Day Vulnerability: What Companies Need to Know

On May 31, 2023, renowned managed file transfer solution provider Ipswitch, Inc. revealed a zero-day vulnerability in its flagship solution, MOVEit Transfer, that can enable mass data theft from thousands of organizations....more

SEC Issues Multiple Cybersecurity Rule Proposals

The Securities and Exchange Commission (SEC) continued its focus on cybersecurity regulations this month by announcing three new proposed rules and re-opening the comment period on an additional proposed rule from last year....more

Banking in the Cloud: How Financial Institutions Can Mitigate the Regulatory and Security Risks

As organizations in the financial sector continue to migrate IT and business services to the cloud and adopt other cloud offerings, it is important that financial institutions understand the risks associated with each. A U.S....more

NCUA Approves New Cyber Incident Reporting Requirements: What Credit Unions Need to Know

The National Credit Union Administration (NCUA) has approved new cyber incident reporting requirements for credit unions. Under the final rule, federally insured credit unions will be required to notify the NCUA of a...more

Financial Industry Regulators Continue Crackdown on Cybersecurity

On multiple fronts, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) continue to increase their focus on cybersecurity. This is understandable as headlines of recent...more

FFIEC Updates Its Guidance on Authentication and Access Controls: Key Takeaways Financial Institutions Should Implement Now

On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC), the multi-agency authority responsible for issuing uniform principles and standards for supervision of financial institutions, published new...more

Another State Privacy Law Hits the Books: What You Need to Know About the Colorado Privacy Act

Earlier this month, Colorado became the third state to pass comprehensive data privacy legislation. As we have previously analyzed, California originally passed the CCPA and the CPRA, then Virginia passed the VCDPA, and now...more

California Privacy Law Update: CCPA Amendments Announced and CPPA Board Members Appointed

California is continuing to make news with respect to its privacy laws. California's Attorney General recently announced the approval of new amendments to regulations of the California Consumer Privacy Act (CCPA). The new...more

NYDFS Surges Ahead with Cybersecurity Enforcement: Recent Fine Highlights Need for Financial Institutions to Focus on Incident...

The New York Department of Financial Services (NYDFS) has become a frequent topic of these alerts. In recent weeks we have covered multiple actions from the regulator, including its first enforcement action, its SolarWinds...more

Key Takeaways from Recent Cyberattack Resulting in Demise of Hedge Fund

We've all heard a lot about cybersecurity risks and how cyberattacks have dramatically increased since COVID-19 changed our daily work environments. A recent attack has resulted in the demise of a hedge fund and illustrates...more

Privacy Legislation Floodgates Have Opened: Virginia Passes the Consumer Data Protection Act

Virginia has become the latest state to pass comprehensive privacy legislation as its legislature voted to enact SB 1392, known as the Consumer Data Protection Act (the "Act"). Although many other states have proposed privacy...more

U.S.'s First Cyber Insurance Risk Framework Issued by New York Department of Financial Services

New York remains extremely active in the cybersecurity and data protection arena. As we have recently discussed, New York is considering a proposed privacy bill that would greatly enhance consumer privacy rights, increase...more

Proposed NY Privacy Bill Would Increase Business Obligations and Litigation/Enforcement Exposure for Businesses, Including...

While California understandably has received most of the attention given its recent passage of the California Privacy Rights Act (CPRA), several other states continue to move forward with consideration of their own privacy...more

Faster and More Comprehensive Breach Notification Requirements Proposed for Banks

The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Company (FDIC), have issued a notice of proposed rulemaking (Proposed Rule) that would require a banking...more

The Year Ahead: Privacy and Cybersecurity Issues Facing Financial Institutions in 2021

The financial services industry faced unprecedented cybersecurity and privacy challenges in 2020. From learning how to operate with a remote workforce, dealing with a complex and evolving regulatory environment, facing an...more

New Ransomware Advisories from OFAC and FinCEN Create Additional Challenges for Financial Institutions

Both the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury have issued advisories recently regarding regulatory considerations financial...more

How California's New(er) Privacy Legislation Will Affect U.S. Businesses

While most of us have been understandably focused on the presidential election, the State of California has passed significant new privacy legislation that may have a substantive impact on your business. Specifically,...more

OCC Issues Guidance on Safekeeping and Custody Services for Cryptocurrency

Late last month, the Office of the Comptroller of the Currency (OCC) issued an Interpretive Letter clarifying that national banks and federal savings associations are authorized to provide safekeeping and custody services for...more

Lessons Learned from the NYDFS First Cybersecurity Regulation Enforcement Action

Last week, the New York Department of Financial Services (NYDFS) filed its first enforcement action against a title insurance company (the company) alleging multiple violations of its Cybersecurity Regulation. New York's...more

Critical Guidance for Financial Institutions on Security Considerations for Cloud Computing Environments

On April 30, 2010, the Federal Financial Institutions Council (FFIEC) issued Guidance on the use of cloud computing services and security risk management principles in the financial services sector. The Guidance reminds...more

SEC Signals How Examinations Will Focus on Compliance with Reg BI and Form CRS

The countdown to June 30, 2020 is on – the deadline by which broker-dealers with retail customers must comply with Regulation Best Interest (Reg BI), and broker-dealers and investment advisers must comply with Customer...more

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