Under the Securities and Exchange Commission’s (SEC) new Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule (cybersecurity rule), public companies subject to the cybersecurity rule must promptly...more
Recent activity by the New York Department of Financial Services (NYDFS) and the Securities and Exchange Commission (SEC) highlight the continued focus by government regulators on cybersecurity. As these and other regulators...more
11/17/2023
/ Corporate Governance ,
Cybersecurity ,
Data Breach ,
Data Security ,
Financial Regulatory Reform ,
Financial Services Industry ,
NYDFS ,
Popular ,
Regulatory Agenda ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation
On July 26, the Securities and Exchange Commission (“SEC”) finalized a much anticipated rule addressing cybersecurity risk management, strategy, governance, and incident disclosure. Public companies registered with the SEC...more
8/8/2023
/ Compliance ,
Corporate Governance ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
New Rules ,
Popular ,
Publicly-Traded Companies ,
Reporting Requirements ,
Required Forms ,
Risk Management ,
Securities and Exchange Commission (SEC)
We have written here previously about the dramatic increase in cyberattacks on companies of all types since the start of the COVID-19 pandemic. Indeed, by some estimates, ransomware attacks have increased over 90% during the...more
On January 8, 2021, Judge Richard Seeborg of the United States District Court for the Northern District of California issued an Order denying a motion to dismiss in S.E.C. v. NAC Foundation, LLC, et al. The U.S. Securities &...more
Earlier this year, the U.S. Department of Justice (“DOJ”) released its highly anticipated Cryptocurrency Enforcement Framework (the “Framework”). The Framework was developed as part of the Attorney General’s Cyber-Digital...more
12/29/2020
/ Biden Administration ,
Bitcoin ,
BSA/AML ,
Commodity Futures Contracts ,
Criminal Investigations ,
Cross-Border Transactions ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
On December 1, 2020, the U.S. Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its Annual Report, which details a “record-breaking” fiscal year 2020 (“FY 2020”), despite the challenges presented...more
On September 17, 2020, the SEC announced the imposition of a cease-and-desist order against private equity firm Welsh, Carson, Anderson & Stowe (Welsh Carson), an SEC-registered investment manager, in connection with alleged...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
9/18/2020
/ Broker-Dealer ,
Compliance ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Protection ,
Identity Theft ,
Investment Adviser ,
Popular ,
Risk Alert ,
Securities and Exchange Commission (SEC)
The SEC, through its Office of Compliance Inspections and Examinations (“OCIE”), recently issued its most detailed cyber guidance to date. OCIE had previously issued several cybersecurity risk alerts over the past few years....more
2/13/2020
/ Corporate Issuers ,
Cybersecurity ,
Data Management ,
Incident Response Plans ,
Internal Controls ,
Investment Adviser ,
New Guidance ,
OCIE ,
Risk Alert ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Security and Privacy Controls ,
Third-Party Service Provider
On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more
5/29/2019
/ Broker-Dealer ,
Cloud Storage ,
Customer Information ,
Cyber Threats ,
Cybersecurity ,
Data Protection ,
Data Security ,
Data Storage Providers ,
Identity Theft ,
Identity Theft Red Flags Rule ,
Investment Adviser ,
OCIE ,
Policies and Procedures ,
Popular ,
Regulation S-ID ,
Regulation S-P ,
Regulatory Requirements ,
Risk Alert ,
Safeguards Rule ,
Securities and Exchange Commission (SEC) ,
Third-Party Service Provider ,
Vendors