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SEC Focus on Cybersecurity Begins to Take Shape

The U.S. Securities and Exchange Commission is implementing a campaign to overhaul the agency’s expectations around cybersecurity and cyber incident reporting for the financial services industry and corporate America...more

SEC Cybersecurity Rules Target Investment Advisers and Investment Companies

On February 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed a package of new rules and amendments to enhance cybersecurity preparedness and improve cyber resilience of investment advisers and investment...more

NYDFS Issues Ransomware Guidance Aimed At Combatting Rising Cyber Threats

The exponential rise in ransomware attacks in the past year has everyone on high alert, not least of which are regulators. Following on the heels of a June 2, 2021 White House memo addressing ransomware prevention, on June...more

Gone Phishing? Wire Fraud Scams Continue Unabated Throughout 2021 So Far

By this point, most businesses that regularly send and receive funds electronically have heard about the risk of wire fraud scams in which an intruder changes wiring instructions and diverts funds to its own account,...more

NYDFS Consent Order Signals Regulator’s Growing Focus On Financial Institutions’ Incident Response And Security Practices

In early March, the New York State Department of Financial Services (“NYDFS”) announced a consent order that required Maine-based mortgage servicer Residential Mortgage Services, Inc. (“Residential”) to pay a $1.5 million...more

Nowhere To Hide: Controllers have “Constructive Awareness” Of Processor Data Breaches

On December 15, 2020, Ireland’s Data Protection Commission (“DPC”) announced its decision to fine Twitter International Company (“Twitter”) €450,000 for failing to notify the DPC promptly of a data breach affecting EU...more

FTC And Zoom Reach Settlement Over Alleged Privacy And Data Security Misrepresentations

On November 9, 2020, the Federal Trade Commission (“FTC”) announced a settlement with Zoom Video Communications, Inc. (“Zoom”) to resolve allegations that the company misled customers about steps it had taken to protect...more

Practical Steps to Reduce Cybersecurity Risks During COVID-19

Cybercriminals love a crisis and COVID-19 is no different. In the last several weeks, cyber-crime has increased exponentially as hackers seek to take advantage of the migration to a remote workplace. As cybercriminals seek to...more

What a Long Strange Trip it's Been: California Legislature Passes Key CCPA Amendments

In the waning days of the legislative session, the California Legislature this month passed several notable measures amending the California Consumer Privacy Act (CCPA). While the Legislature surprised many by rejecting a...more

SEC Report Cautions Public Companies on Internal Controls and Cybersecurity Risks

The Securities and Exchange Commission (the Commission) has published a report of an investigation (the Report) into whether certain public companies that suffered financial losses as a result of cyber-related fraud violated...more

DHS and NIST Issue Internet of Things Cybersecurity Guidance

In an apparent effort to fight the kinds of cyberattacks like the massive distributed denial-of-service (DDoS) attack that crippled much of the American internet in October 2016, the Department of Homeland Security (DHS)...more

2016: The Year of Cyber Insurance?

It has been said that there are two types of companies in the world – those that have been hacked, and those that do not yet know they have been hacked. While perhaps an overstatement, it seems that every day, another company...more

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