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Cyber Risk

SEC Issues Risk Alert Noting Common Regulation S-P Compliance Issues

April 18, 2019 By Kate Hanniford

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the Safeguards Rule, Regulation S-P, based on recent examinations.  Placed in context with prior OCIE Risk Alerts concerning cybersecurity practices and Regulation S-P […]

Filed Under: Cyber Risk, Data Protection, Data Security, Financial Privacy, Privacy Policy, Regulation

Companion Cybersecurity Disclosure Bills Introduced in U.S. Congress

March 20, 2019 By Kate Hanniford

On February 28 and March 13, 2019, members of the U.S. Senate and U.S. House of Representatives introduced legislation designed to enhance the transparency of cybersecurity risk oversight at certain SEC reporting companies. Although the text of the House bill, H.R. 1731 is not yet publicly available, the bipartisan Senate bill, S. 592, would require […]

Filed Under: Cyber Risk, Cybersecurity, Legislation, Regulation

SEC Investigative Report Cautions Public Companies to Consider Cyber Threats When Implementing Internal Accounting Controls

October 22, 2018 By Kate Hanniford and Privacy, Cyber & Data Strategy Team

The Securities and Exchange Commission issued an investigative report last week cautioning public companies to consider cyber incidents and threats when implementing internal accounting controls.  The report details the SEC Enforcement Division’s investigations of nine public companies that were victims of cyber-related fraud schemes to determine whether the companies may have violated the federal securities […]

Filed Under: Cyber Risk, Cybersecurity, Data Security Tagged With: Securities and Exchange Commission

NIST Releases Updated Cyber Framework V1.1

December 6, 2017 By Privacy, Cyber & Data Strategy Team

On December 5, 2017, the National Institute of Standards and Technology (NIST) released a revised draft of its proposed updates to its Framework for Improving Critical Infrastructure Cybersecurity. The revised draft includes a new section on communicating with stakeholders about cybersescurity requirements, addresses stakeholder concerns regarding cybersecurity supply chain risk management and measuring cybersecurity risks […]

Filed Under: Cyber Risk, Cybersecurity Tagged With: Cybersecurity, National Institute for Standards and Technology (NIST)

FTC Updates Data Security Guidance for Businesses

August 2, 2017 By Privacy, Cyber & Data Strategy Team

In June, the Federal Trade Commission released a new guide for businesses on implementing sound data security protections and procedures. In “Protecting Personal Information: A Guide For Business,” the FTC offers “10 practical lessons” based on the numerous enforcement actions brought by the FTC. The guide offers insight into the thinking of this key federal […]

Filed Under: Cyber Risk, Cybersecurity, Data Protection, Data Security, Enforcement, Online Privacy, Privacy Tagged With: Federal Trade Commission (FTC)

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