News & Analysis as of May 6, 2025

Enforcement Actions

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

NFL Draft Provides Wake-Up Call on Protecting Confidential Information While Working Remotely

Paul Hastings LLP on 5/5/2025

Last week’s NFL draft highlighted more than the accomplishments of athletes at the combine or on the field. While there was extensive coverage of the merits of each player, one of the major headlines coming out of the draft...more

SEC Charges Public Companies with Misleading Cyber Disclosures

Husch Blackwell LLP on 11/26/2024

On October 22, 2024, the Securities and Exchange Commission (SEC) announced that it had charged four companies with making materially misleading disclosures regarding cybersecurity risks and intrusions, with one company also...more

In This Month’s E-News: November 2024

Health Care Compliance Association (HCCA) on 11/4/2024

On the heels of a $7.6 million payment by Cleveland Clinic to settle allegations of False Claims Act (FCA) violations and unallowable sharing of passwords, Michael Lauer, NIH deputy director for extramural research, penned a...more

SEC Revamps and Enhances Data Protections with Amendments to Regulation S-P

Foley Hoag LLP - Security, Privacy and the... on 5/30/2024

The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more

Understanding SEC’s Focus Amid Lack of Final AI Rules

Skadden, Arps, Slate, Meagher & Flom LLP on 2/27/2024

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

Investment Adviser Expectations in 2024

Davis Wright Tremaine LLP on 1/19/2024

Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more

OCR Ends Year With Settlements That Tread Old Ground, Says New Rules Are Coming—Someday

Health Care Compliance Association (HCCA) on 1/17/2024

If the penultimate enforcement settlement of 2023 issued by the HHS Office for Civil Rights (OCR) sounds familiar, that’s with good reason. And the last one of the year should ring some bells, too....more

[Event] 28th Annual Compliance Institute - April 14th - 17th, Nashville, TN

Health Care Compliance Association (HCCA) on 12/5/2023

Get ready to be inspired with game-changing insights and industry connections! For over two and a half decades, healthcare compliance professionals have gathered at HCCA’s Compliance Institute (CI) to share ideas, learn...more

Investment Management Update - November 2023

Skadden, Arps, Slate, Meagher & Flom LLP on 11/16/2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

The SEC's Proposed Cybersecurity Rules: Regulatory Delay Does Not Bless Standing By

BakerHostetler on 7/21/2023

The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

Jenner & Block on 7/11/2023

Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

Crypto trading platform reaches $1.2 million settlement to resolve alleged compliance failures

Orrick, Herrington & Sutcliffe LLP on 5/12/2023

On May 1, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of the state’s cybersecurity regulation (23 NYCRR Part 500)...more

FTC Actions Hold Data Privacy Lessons For 2023

Rothwell, Figg, Ernst & Manbeck, P.C. on 1/4/2023

The Federal Trade Commission will have its eye on privacy and data security enforcement in 2023. In August, the agency announced that it is exploring ways to crack down on lax data security practices. In the announcement,...more

Wealth Management Firm Charged with Reg S-P Violations for Failing to Properly Dispose of its Hard Drives

Seward & Kissel LLP on 10/5/2022

On September 20th, 2022, the Securities and Exchange Commission (“Commission”) entered a settled order (“Order”) against the wealth management arm of a global financial services firm (“Firm”) for its failure to protect...more

The SEC Wants You to Take Out the Trash – Securely

Vinson & Elkins LLP on 9/23/2022

In a recent Securities and Exchange Commission (“SEC”) enforcement action, the SEC concluded that a registered broker-dealer and investment adviser (the “Firm”) violated Rule 30 of Regulation S-P by failing to adopt...more

U.S. and British Law Enforcement Agencies Issue Unprecedented Warning About Chinese Espionage Efforts

Foley & Lardner LLP on 7/12/2022

On July 6, 2022, the heads of the U.S. Federal Bureau of Investigation (FBI) and the British MI5 law enforcement agencies issued an unprecedented joint statement warning about espionage and other economic threats from China....more

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

Holland & Knight LLP on 2/24/2022

Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

SEC Chair Gensler Remarks Indicate 2022 Action Expanding Cyber Requirements

Holland & Knight LLP on 1/31/2022

U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler made remarks on Jan. 24, 2022, at Northwestern University Pritzker School of Law's Annual Securities Regulation Institute regarding the SEC's work to improve...more

DOJ Announces Civil Cyber-Fraud Initiative To Enforce Contractor Cybersecurity Compliance

Sheppard Mullin Richter & Hampton LLP on 10/29/2021

On Wednesday, October 6, 2021, the Department of Justice (“DOJ”) announced a new Civil Cyber-Fraud Initiative to enforce cybersecurity standards and reporting requirements. The Initiative will use DOJ’s civil enforcement...more

DOJ’s Civil Cyber-Fraud Initiative Highlights False Claims Act Cybersecurity Risks for Government Contractors

Perkins Coie on 10/12/2021

On October 6, 2021, the U.S. Department of Justice (DOJ) announced an initiative to pursue civil False Claims Act (FCA) enforcement actions against government contractors that knowingly fail to follow required cybersecurity...more

[Virtual Event] Washington DC Regional Compliance & Ethics Conference - October 8th, 8:25 am - 4:30 pm EDT

Society of Corporate Compliance and Ethics... on 10/5/2021

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

SEC Makes Cybersecurity Top Priority; Sanctions Firms for Cybersecurity Failures

Goodwin on 9/16/2021

There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more

SEC Cyber Enforcement Actions – Lessons for Private Fund Managers

Akin Gump Strauss Hauer & Feld LLP on 9/9/2021

On August 30, 2021, the Securities and Exchange Commission announced three enforcement actions against registered investment advisers for alleged cybersecurity failures involving cloud-based email systems. All three actions...more

NYDFS—First Enforcement Action under Cybersecurity Regulation

McDermott Will & Emery on 7/30/2020

On July 21, 2020, the New York Department of Financial Services (NYDFS) announced that it had filed its first enforcement action under 23 NYCRR 500 (the “Cybersecurity Regulation”) against First American Title Insurance (the...more

[Virtual Event] 2020 COVID-19 Essentials for Healthcare Compliance Programs - July 21st, 11:00 am CT

Health Care Compliance Association (HCCA) on 6/19/2020

HCCA has assembled a half-day virtual conference to help compliance professionals stay on top of the fast-moving changes caused by the COVID-19 pandemic. By participating in this event, you will hear directly from the...more

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Cybersecurity › Policies and Procedures › Enforcement Actions

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