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 […]
On May 11, 2017, President Trump signed a long-awaited executive order on cybersecurity (the “Order”). The Order directs executive agencies to complete a risk management report based on the NIST Cybersecurity Framework (the “Framework”) and also requires the Department of Homeland Security (DHS) and other agencies to undertake activities in support of effective cybersecurity risk […]
Europe is facing two important reforms addressing cybersecurity, which will apply in 2018. Jan Dhont and Delphine Charlot outlined the details of these regimes in an article for the Society of Corporate Compliance and Ethics, which you can read here.
More regulators (apart from the FTC) are now taking note of cybersecurity issues in the financial services industry and are taking steps to protect the industry and its consumers. Earlier this year, the Consumer Financial Protection Bureau (“CFPB”) issued its first enforcement action on data security against an online payment system. In June, the Federal […]
On September 13, 2016, Governor Andrew Cuomo announced the issuance of proposed “first-in-the-nation” cybersecurity regulations for entities regulated by the New York Department of Financial Services (DFS), including jurisdictional banks, insurance companies, and other financial institutions. The proposed regulation will be subject to a 45-day comment period prior to being issued as a final rule. […]