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Security Risk Assessments Securities and Exchange Commission (SEC)

Morgan Lewis

SEC Proposes Cybersecurity Incident Reporting and Broker-Dealer Cyber Risk Management Requirements

Morgan Lewis on

The US Securities and Exchange Commission (SEC) issued a notice of proposed rulemaking (the Proposal) on March 15 that would require SEC-regulated investment advisers, investment companies, and broker dealers to provide...more

BakerHostetler

New CBDC and NFT Data Released; OFAC Adds Mixer and Public Keys to SDN List; Multiple Crypto Enforcement Actions; Stablecoin Risks...

BakerHostetler on

BIS Releases Survey on CBDC Initiatives; New Crypto Products Launch - The Bank for International Settlements (BIS) recently released the results of its 2021 survey of central bank digital currencies (CBDCs). According to...more

Moore & Van Allen PLLC

SEC Announces Exam Priorities for 2022

On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations released its exam priorities for fiscal year 2022 (the “2022 Priorities”). As in years past, these exam priorities naturally...more

Holland & Knight LLP

SEC Issues First-Ever Penalties for Deficient Cybersecurity Risk Controls

Holland & Knight LLP on

The U.S. Securities and Exchange Commission (SEC) has launched a stunning salvo across the bows of public companies with its announcement of civil monetary penalties and a cease-and-desist order against First American...more

White & Case LLP

Ensuring an Effective Cybersecurity Program: Best Practices from the SEC and OCIE

White & Case LLP on

The Securities and Exchange Commission (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) recently released a report summarizing best practices for securities market participants, including public companies,...more

Proskauer Rose LLP

OCIE Publishes Cybersecurity and Resiliency Observations

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Background - On January 27, 2020, the U.S. Securities and Exchange Commission's Office of Compliance Inspections and Examinations ("OCIE") published its Cybersecurity and Resiliency Observations. Cybersecurity and data...more

Manatt, Phelps & Phillips, LLP

Cybersecurity Guidance on SEC Horizon

In a push for increased cybersecurity vigilance, the Securities and Exchange Commission indicated its plans to amend existing data security guidance, including the reporting of data breaches....more

Polsinelli

SEC’s Most Recent Cybersecurity Move: What Registered Investment Advisors Need to Know

Polsinelli on

As public concern over data security grows in the wake of the Equifax data breach, the U.S. Securities and Exchange Commission (SEC) is increasing its scrutiny of registered investment advisors (RIAs). In turn, RIAs should...more

Burr & Forman

SEC’s Cybersecurity Risk Alert Reflects Advisory Firms are Gambling with Your Data

Burr & Forman on

In August 2017, the SEC’s Office of Compliance Inspections and Examinations issued a Cybersecurity risk alert directed at financial advisory firms. As part of the SEC’s 2014 Cybersecurity Initiative, seventy-five firms,...more

Bradley Arant Boult Cummings LLP

SEC Examination Priorities for 2017 – What do Robots, Senior Investors, and Payment for Order Flow Have in Common?

This week, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released its Examination Priorities for 2017 that reflects certain practices, products, and services that OCIE perceives to present potentially...more

Proskauer on Privacy

SEC Cybersecurity Update

Proskauer on Privacy on

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Snell & Wilmer

SEC Announces Second Wave of Cyber Exams of Broker Dealers and Advisors – Is Your Firm Ready?

Snell & Wilmer on

In April 2014, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert announcing its first cybersecurity sweep initiative. Pursuant to that initiative,...more

Morgan Lewis

Proactive Approach To Cybersecurity: Recent SEC guidance and enforcement actions suggest that reactive firms may be in the SEC’s...

Morgan Lewis on

In an environment where even the largest and most powerful corporations have fallen victim to data breaches, it can be challenging to fathom how to protect against the sophisticated and ever-evolving threat of cyber attacks....more

King & Spalding

Investment Adviser Settles SEC Cybersecurity Enforcement Action; SEC Issues Investor Alert

King & Spalding on

On September 22, the U.S. Securities and Exchange Commission (“SEC”) and R.T. Jones Capital Equities Management, Inc. (“R.T. Jones”), a St. Louis-based investment adviser, settled charges that R.T. Jones failed to adopt...more

Foley & Lardner LLP

SEC Brings First Cybersecurity Enforcement Proceeding in Wake of Risk Alert

Foley & Lardner LLP on

Highlights Areas of High Risk and Examination Priorities for Financial Industry Firms - On September 15, the U.S. Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections and Examinations (OCIE),...more

Manatt, Phelps & Phillips, LLP

SEC Ramps up Cybersecurity Scrutiny With Examination Priorities and an Enforcement Action

Why it matters - Signaling that it will continue to increase its scrutiny of firms' cybersecurity readiness, the Office of Compliance, Inspections and Examinations of the Securities and Exchange Commission (SEC) issued a...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more

Foley Hoag LLP - Security, Privacy and the...

The SEC Charges Investment Adviser with Violating Regulation S-P by Failing to Adopt Cybersecurity Policies and Procedures

In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to...more

Broker-Dealer Compliance + Regulation

SEC Charges Investment Adviser With Failure to Adopt Proper Cybersecurity Policies and Procedures

A registered investment adviser agreed to settle SEC charges that it failed to adopt adequate cybersecurity policies and procedures reasonably designed to protect customer records and information as required by Rule 30(a) of...more

Proskauer on Privacy

SEC Announces Cybersecurity Enforcement Action

Proskauer on Privacy on

On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation...more

King & Spalding

Unprecedented Hacking and Trading Scheme Highlights Key Cybersecurity Lessons

King & Spalding on

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

Alston & Bird

SEC Provides Additional Information On Cybersecurity Examinations

Alston & Bird on

On September 15, 2015, the Security and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide additional information on the areas of focus for its second round of...more

Foley Hoag LLP

OCIE’s 2015 Cybersecurity Examination Initiative

Foley Hoag LLP on

Second Round of Cybersecurity Examinations to Begin - On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a...more

Morgan Lewis

National Futures Association Proposes Cybersecurity Guidance for NFA Member Firms

Morgan Lewis on

NFA links NFA’s supervisory requirements with its proposed requirements mandating that NFA Members have information systems security programs. The National Futures Association (NFA) has proposed cybersecurity...more

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