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Kate Hanniford

NYDFS Issues Best Practices for Cyber Insurance Risk Management

February 18, 2021 By Kate Hanniford

Against the backdrop of the disruptions associated with the Covid-19 pandemic and SolarWinds cyber-espionage campaign, NYDFS has released guidance for insurers that underwrite cyber insurance policies and which contains a number of provisions expected to impact companies applying for or renewing cyber insurance coverage, not the least of which is a specific recommendation that insurers […]

Filed Under: Advisories, Cyber Risk, Cybersecurity, NYDFS

Fifth Circuit Decision Raises Cyber Enforcement Complications for the U.S. Department of Health and Human Services

February 9, 2021 By Jon Knight and Kate Hanniford

As the Biden administration begins detailing its regulatory and enforcement priorities, it faces a new challenge on the health data privacy and security front.  In University of Texas M.D. Anderson Cancer Center v. United States Department of Health and Human Services, No. 19-60226 (5th Cir. 2021), the Fifth Circuit vacated a $4.3 million penalty against […]

Filed Under: Enforcement, Health Privacy, HHS, Regulation

SEC Focused on Protecting Customer Accounts from Credential Stuffing Attacks

September 24, 2020 By Kate Hanniford

OCIE has released a risk alert regarding credential stuffing in the context of compliance with Regulation S-P and Regulation S-ID, and is encouraging firms to both (i) review and update their policies and procedures to address the risks associated with credential stuffing and (ii) consider proactive outreach to customers regarding measures taken to safeguard their […]

Filed Under: Cybersecurity, Dark Web, Data Security, Financial Privacy, Regulation

SEC Creates Event and Emerging Risk Examination Team

July 28, 2020 By Kate Hanniford

Following OCIE’s recent and detailed risk alert regarding the threat of ransomware, the SEC today announced that it has created the Event and Emerging Risk Examination Team (EERT) as a part of the Office of Compliance Inspections and Examinations (OCIE).  The EERT will engage with registrants regarding emerging threats and current market events, to provide […]

Filed Under: Cyber Risk, Cybersecurity

SEC’s OCIE Issues Ransomware Risk Alert

July 13, 2020 By Kate Hanniford

On July 10, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert noting the increasing sophistication of ransomware attacks on SEC registrants and service providers to SEC registrants.  The Risk Alert is notable for its encouragement of financial services market participants more broadly and not just SEC registrants to monitor CISA […]

Filed Under: Advisories, Cyber Risk, Data Security

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