News & Analysis as of

Data Security Risk Management Financial Institutions

Orrick, Herrington & Sutcliffe LLP

OIG makes seven recommendations for CFPB following major incident

On May 5, the OIG for the Fed authored a report with several recommendations for the CFPB following a major security incident regarding confidential supervisory information (CSI). The OIG issued four findings with seven...more

Hogan Lovells

NYDFS: Penultimate set of cybersecurity requirements under amended Part 500 take effect May 1, 2025

Hogan Lovells on

On May 1, 2025, additional cybersecurity requirements introduced by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) took...more

Sheppard Mullin Richter & Hampton LLP

North Dakota Expands Data Security Requirements and Issues New Licensing Requirements for Brokers

On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates...more

A&O Shearman

FSB publishes finalised format for FIRE framework

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The Financial Stability Board (FSB) has published its finalised Format for Incident Reporting Exchange (FIRE), together with a press release and updated webpage. FIRE provides a standardised format for financial institutions...more

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Quarles & Brady LLP

New York Cybersecurity Regulation Requires Submission of Compliance Certification or Acknowledgement of Noncompliance Next Week

Quarles & Brady LLP on

On April 3, 2025, the New York State Department of Financial Services (“DFS”) issued reminders about upcoming implementation and reporting deadlines related to its cybersecurity regulations. Upcoming deadlines require...more

Integreon

DORA Compliance Part 2: Addressing Compliance Across Critical Operational Areas

Integreon on

Introduction to DORA and its Implications - As of Jan.17, 2025, the European Union’s Digital Operational Resilience Act (DORA) became enforceable. This new regulatory framework significantly impacts financial institutions and...more

Quarles & Brady LLP

Warning! ChatGPT Exploit Used by Threat Actors in Cyber Attacks

Quarles & Brady LLP on

Members of the health care and financial industries, along with other industries that hold sensitive data, are warned that a ChatGPT vulnerability is being actively exploited by threat actors to attack security flaws in AI...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Reminder: New York Cybersecurity Reporting Deadline April 15, 2025; New Regulations Effective May 1, 2025

Covered entities regulated by the New York State Department of Financial Services (NYDFS) must submit cybersecurity compliance forms by April 15, 2025. New sets of requirements for system monitoring and access privileges,...more

McGlinchey Stafford

The Next Wave of Open Banking: New Rules on Personal Financial Data Rights

McGlinchey Stafford on

A rapid transformation in consumer finance is being brought about by open banking—a pivotal innovation that allows consumers to give third parties real-time access to their detailed financial data. Open banking has the...more

A&O Shearman

ESAs roadmap for designation of critical ICT third-party service providers under DORA

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The European Supervisory Authorities (ESAs) have published a roadmap for the designation of critical ICT third-party service providers (CTPPs) under the EU Digital Operational Resilience Act (DORA). The roadmap of key dates...more

Constangy, Brooks, Smith & Prophete, LLP

Cryptocurrency hacks and thefts: Insecure exchanges?

Cryptocurrency exchanges continue to be a target of hackers – and theft is the prize. On February 21, the cryptocurrency exchange Bybit reported that an Ethereum transaction was transferred to an unidentified address,...more

Harris Beach Murtha PLLC

May 1 Deadline for Amendments to NY Department of Financial Services Cybersecurity Standard

New York State’s Department of Financial Services is warning all regulated entities has released a Cybersecurity Regulation Updates and Reminder warning all companies that all regulated entities without a full exception that...more

A&O Shearman

European Central Bank updates TIBER-EU framework to align with DORA RTS on TLPT

A&O Shearman on

The European Central Bank (ECB) has published an updated version of the threat intelligence-based ethical red teaming framework (TIBER-EU framework) (dated January) to align with the Digital Operational Resilience Act (DORA)...more

A&O Shearman

European Banking Authority publishes amending guidelines on ICT and security risk management in the context of DORA

A&O Shearman on

The European Banking Authority (EBA) has published a final report with amending guidelines in respect of Guidelines EBA/GL/2019/04 on ICT and security risk management. The EBA reviewed the Guidelines in light of the Digital...more

A&O Shearman

European Commission adopts Delegated Regulation on RTS on threat-led penetration testing under DORA

A&O Shearman on

The European Commission (EC) has adopted a Commission Delegated Regulation supplementing the Digital Operational Resilience Act (DORA) with regard to RTS specifying the criteria used for identifying financial entities...more

Orrick, Herrington & Sutcliffe LLP

CFPB’s union raises concerns over security and alleged misuse of sensitive information

On February 7, the union representing CFPB employees published a notice expressing concerns regarding the recent addition of certain DOGE employees to the CFPB’s email directory and their presence in offices. ...more

Orrick, Herrington & Sutcliffe LLP

Cyber Threats in Public Finance: Protecting Transactions from Wire Fraud

A recent cyberattack on a Michigan township has exposed weaknesses in the bond-closing process. In this incident, hackers stole over $25 million in bond proceeds by using spoofed email addresses to provide fraudulent wire...more

Morgan Lewis - Tech & Sourcing

DORA European Commission Clarifies Scope of ICT Services

European regulators recently published clarifications on the scope of ICT services under the EU Digital Operational Resilience Act (DORA), prepared by the European Commission, which confirms previous guidance and enables...more

McDermott Will & Emery

Data Privacy and Cybersecurity in 2025: PCI DSS 4.0

McDermott Will & Emery on

Following our recent client alert, learn more about PCI DSS 4.0 coming into effect and its impact on organizations in 2025. Mark Schreiber, Brian Long, and Sam Genovese share further insights from working with clients on...more

Cadwalader, Wickersham & Taft LLP

DORA Now in Force in the EU

Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (“DORA”), which establishes a uniform set of requirements relating to the security of network and information systems supporting financial...more

Mayer Brown

Cybersecurity in the Financial Sector: EU’s Digital Operational Resilience Act Takes Effect

Mayer Brown on

Beginning 17 January 2025, the Digital Operational Resilience Act (DORA) will apply to almost all EU financial entities, including banks, insurers and reinsurers, brokers , payment and electronic money institutions,...more

DLA Piper

DORA: Navigating the New Era of Digital Operational Resilience in EU Financial Services

DLA Piper on

It’s DORA day! The EU financial services sector has been anticipating today since the Digital Operational Resilience Act was published in December 2022. DORA brings a significant shift to the sector in terms of how financial...more

Walkers

Navigating DORA: Key compliance steps from 17 January 2025

Walkers on

DORA is now applicable, imposing requirements in respect of ICT risk management and digital operational resilience. Firms should be preparing their register of information ready for sharing with the CBI in April....more

A&O Shearman

Business email compromise and invoice fraud – a duty of care on the innocent?

A&O Shearman on

The Western Australian District Court’s recent decision in Mobius Group Pty Ltd v Inoteq Pty Ltd1 highlights the potential consequence for the innocent party where fraudulent changes in bank details are sent from their...more

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