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While uncertainty continued to loom over the CFPB, the states did not take a spring break. Instead, we saw an eye-popping settlement from NY DFS involving BSA/AML claims. And both republican and democratic AGs continued to...more
On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by...more
Selected U.S. Privacy and Cyber Updates - New York AG Seeks Comments on Rulemaking for Minors’ Online Protection Laws - On August 1, 2024, New York Attorney General Letitia James issued two advanced notices of proposed...more
AML Developments - What You Need to Know - Earlier this month, the New York State Department of Financial Services (“DFS”) and the Federal Reserve Board of Governors (“FRB”) announced settlements with the Industrial and...more
Cyber, Privacy, and Technology Report - Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed....more
Recent enforcement actions and announcements show that state and federal regulators are continuing to focus intensely on cybersecurity and data protection. Notably, the New York Department of Financial Services (“NYDFS”)...more
On May 1, NYDFS settled with a cryptocurrency trading platform over the company’s cybersecurity deficiencies, resulting in a consent order and $1.2 million fine for the crypto company. NYDFS alleged “multiple deficiencies in...more
On March 16, NYDFS entered a consent order resolving an examination of a payment service provider that allows merchants to accept Bitcoin payments from customers in exchange for the equivalent value in local currency credited...more
The New York and Pennsylvania AGs settlement with Herff Jones from late last year provides guidance to businesses about expected security measures as we enter into 2023. The case arose after Herff Jones, producer and seller...more
On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more
New York’s Department of Financial Services (“DFS”) recently announced a $100 million settlement with Coinbase, Inc., one of the world’s largest cryptocurrency exchanges, for Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”)...more
On January 4, 2023, the New York State Department of Financial Services issued a consent order against Coinbase, a virtual currency company. Pursuant to the consent order, Coinbase will be paying a $50 million penalty to the...more
In a recent settlement with the New York Department of Financial Services, EyeMed Vision Care LLC agreed to pay a $4.5 million penalty and undertake remedial measures to increase its cybersecurity. This includes undertaking...more
On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic...more
This summer was a busy one for cryptocurrency regulators, with aggressive actions potentially signaling an increase in consumer protection compliance activity. In August alone, the New York Department of Financial Services...more
On June 24, 2022, the New York Department of Financial Services (“DFS”) announced a cybersecurity settlement with Carnival Corporation d/b/a Carnival Cruise Line, Princess Cruise Lines, Holland America Line, Seabourn Cruise...more
Selected Developments in U.S. Law - NYDFS Issues Report on the SolarWinds Attack and Covered Entities’ Responses Following the SolarWinds cyber espionage attack and the resulting focus on supply chain risk, the New York...more
On April 14, 2021, the New York Department of Financial Services (“DFS”) announced a cybersecurity settlement with insurance company National Securities Corporation, which suffered four separate breaches, two of which went...more
Earlier this month, the New York State Department of Financial Services (NYDFS) announced a settlement and consent order with National Securities Corporation (National Securities) for $3 million in connection with National...more
On April 14, 2021, the New York Department of Financial Services (“NYDFS”) announced a settlement with National Securities Corporation (“National Securities”), a licensed insurer, in connection with claims under the NYDFS...more
The New York State Department of Financial Services (DFS) announced the $1.5 million settlement of its investigation of Residential Mortgage Services (RMS) surrounding the unauthorized access to an email account which...more
New York’s Department of Financial Services (“DFS”) announced on Wednesday, March 3, 2021, that an independent mortgage lender, Residential Mortgage Services Inc. (“RMS”), has agreed to pay a $1.5 million fine to the agency...more
In early March, the New York Department of Financial Services (NYDFS) announced a settlement involving a $1.5M penalty and mandatory remediation in response to a mortgage lender’s alleged failure to report a cyber breach, and...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
Recent high profile matters serve as a solemn reminder that marketing techniques in the insurance business are highly regulated and that the simple act of marketing an insurance product can be a risky and costly endeavor....more