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Goodwin

EU AI Act: Key Points for Financial Services Businesses

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The European Union (EU) Artificial Intelligence Act (AI Act), Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending...more

King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

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The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

WilmerHale

SEC Proposes to Expand Reg SCI

WilmerHale on

The Securities and Exchange Commission (SEC) proposes to amend Regulation Systems Compliance and Integrity (Reg SCI) to update and expand the regulatory oversight of the core technology of the U.S. securities markets.1 The...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

Holland & Knight LLP on

The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Sullivan & Worcester

SEC’s Proposed Changes to Regulation S-P Would Overhaul Records and Information Requirements of Covered Institutions

Sullivan & Worcester on

On March 15, 2023, the United States Securities and Exchange Commission (“SEC”) proposed amendments to Regulation S-P that, if finalized, would place additional burdens on covered institutions when it comes to handling...more

Goodwin

SEC Focus on Cybersecurity Begins to Take Shape

Goodwin on

The U.S. Securities and Exchange Commission is implementing a campaign to overhaul the agency’s expectations around cybersecurity and cyber incident reporting for the financial services industry and corporate America...more

BCLP

Supervision of Vendors When Outsourcing - The Buck Stops with FINRA Member Firms

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Key Takeaways: ..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more

A&O Shearman

Significant Business Disruptions: Considerations for Broker-Dealers

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In light of the threats posed by natural disasters, pandemics and civil disorder, among other events, businesses of all types must formulate responses to address significant business disruptions (“SBDs”) and the safety of...more

Sheppard Mullin Richter & Hampton LLP

SEC and FINRA Signal Renewed Focus on Vendor Management in Two Key Areas: Cybersecurity and Market Access Rule Compliance

The Securities and Exchange Commission (“SEC”) and Financial Industry Regulatory Authority (“FINRA”) recently issued guidance in connection with firms’ relationships with third-party service providers. These publications...more

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisors’ and Broker-Dealers’ Cloud-Based and Other Network Storage of Customer Data

• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more

Faegre Drinker Biddle & Reath LLP

U.S. Securities and Exchange Commission Issues Risk Alert Regarding Safeguarding Customer Records and Information Stored on...

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

Carlton Fields

SEC Warns About Third-Party Destruction of Broker-Dealer Records

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The SEC staff issued an April 12 letter addressing broker-dealer contracts with third-party recordkeeping service providers under which the service provider can delete or discard records of a broker-dealer who fails to pay...more

White and Williams LLP

South Carolina’s New Insurance Data Security Act: Pebbles Before a Landslide?

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The ramp-up of cybersecurity regulation, albeit in a patchwork fashion through state-level legislation, has begun. On May 18, 2018, South Carolina enacted the Insurance Data Security Act (Act), becoming the first state to...more

WilmerHale

SEC Proposes Significant Regulatory Changes for Alternative Trading Systems

WilmerHale on

On November 18, 2015, the Securities and Exchange Commission (“SEC” or “Commission”) proposed significant changes to the regulatory requirements applicable to dark pools and other alternative trading systems (“ATSs”) that...more

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

Perkins Coie on

The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

BakerHostetler

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

BakerHostetler on

On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more

King & Spalding

Unprecedented Hacking and Trading Scheme Highlights Key Cybersecurity Lessons

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On Aug. 11, 2015, federal prosecutors in the District of New Jersey and the Eastern District of New York unsealed indictments against nine individuals in the U.S. and Ukraine who were allegedly involved in a five-year,...more

Troutman Pepper

OCIE Cybersecurity Risk Alert: Keep Your Data Close and Your Third-Party Providers Closer

Troutman Pepper on

On February 3, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert that summarizes the OCIE’s observations from its recent examinations of registered...more

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