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Chief Information Security Officer (CISO) Cyber Incident Reporting Cybersecurity

Ankura

Navigating the NY DFS Cybersecurity Amendments: A Timeline for 2024 Through 2025

Ankura on

In December 2023, the New York Department of Financial Services (NY DFS) issued amendments to the cybersecurity requirements, originally adopted in 2017, which include expanded control requirements and stricter reporting...more

Steptoe & Johnson PLLC

New York Federal Court Refuses to Extend Accounting Controls Requirements to Cybersecurity Controls

Section 13(b)(2)(B) of the Securities Exchange Act of 1934 requires public companies to “devise and maintain a system of internal accounting controls.” In a recent opinion, a New York federal court rejected the Securities...more

Skadden, Arps, Slate, Meagher & Flom LLP

Takeaways From the Dismissal of SEC Claims Against SolarWinds and Its CISO

The U.S. District Court for the Southern District of New York has dismissed many of the Securities and Exchange Commission’s (SEC’s) claims against software development company SolarWinds and its chief information security...more

Holland & Knight LLP

SEC Cyber Enforcement Update: Which Way Are the SolarWinds Blowing?

Holland & Knight LLP on

The SEC has been aggressively pursuing cybersecurity investigations and enforcement actions against public companies and foreign private issuers. In these actions, the SEC often alleges one of two theories: 1) that the...more

Vinson & Elkins LLP

Double-Edged Disclosure: Navigating 10-K Season with the SEC’s New Cybersecurity Disclosure Rules

Vinson & Elkins LLP on

Public companies are now required to comply with new cybersecurity disclosure requirements in their Annual Reports on Form 10-K for fiscal years ending on or after December 15, 2023. In preparing this cybersecurity...more

A&O Shearman

Chief information Security Officers and cyber whistleblowing: considerations for boards and breach response teams

A&O Shearman on

At this point, it is self-evident that companies are grappling with an ever-evolving (think: tougher) cyber risk terrain. However, two recent cases against companies and their Chief Information Security Officers (CISOs),...more

Lowenstein Sandler LLP

The SEC Cybersecurity Rules Are Now Effective: What You Need to Know and Do Now

Lowenstein Sandler LLP on

The Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies (the “Cybersecurity Rules”), which the Securities and Exchange Commission (SEC) had adopted earlier this year,...more

McGlinchey Stafford

New York Cybersecurity Regulation Amended and Expanded

McGlinchey Stafford on

On November 1, 2023, the New York Department of Financial Services (NYDFS) adopted amendments to its Cybersecurity Regulation, 23 NYCRR Part 500 (Cybersecurity Regulation). This is the second amendment (Amendment) to its...more

Bradley Arant Boult Cummings LLP

Federal Government Continues Its Big Push for Cybersecurity with SEC Action Against SolarWinds and Its CISO

On October 30, 2023, the Securities and Exchange Commission (SEC) announced a civil suit against SolarWinds and their chief information security officer (CISO) for fraudulent cybersecurity information. The SEC claims that...more

Akin Gump Strauss Hauer & Feld LLP

SEC Turning Up the Heat: SolarWinds and Its CISO Charged with Fraud Regarding Cyber-related Disclosures

Key Takeaways - With the SolarWinds enforcement action, the SEC continues to ratchet up its enforcement against companies that fail to properly disclose their cybersecurity incidents and risks. By naming the SolarWinds CISO...more

Dechert LLP

Dechert Cyber Bits - Issue 45

Dechert LLP on

The Biden Administration Issues Executive Order on Artificial Intelligence - On October 30, 2023, President Biden signed an Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence (the “Order”)...more

Morrison & Foerster LLP

A New Frontier for SEC Cybersecurity Enforcement? The SEC Charges SolarWinds and its CISO with Securities Fraud

Earlier this week, the SEC accused SolarWinds Corporation (“SolarWinds” or the “Company”) and its Chief Information Security Officer (“CISO”) of committing scienter-based securities fraud, among other violations, for...more

Ankura

[Webinar] SEC New Cybersecurity Final Rule: A Different Perspective from the Viewpoints of the CISO, General Counsel, & The Board...

Ankura on

Any time a regulation is put forth, there is always a level of uncertainty, especially regarding understanding the roles and responsibilities of key business leaders. The SEC’s new cybersecurity final rule means heightened...more

Guidepost Solutions LLC

The SEC has new Cybersecurity Rules. Are you prepared and ready?

On July 26, 2023, the Securities and Exchange Commission (SEC) implemented new cybersecurity rules to require disclosure of material cybersecurity incidents within four business days, with limited exceptions.  Additionally,...more

Latham & Watkins LLP

SEC Adopts Cybersecurity Disclosure Rules

Latham & Watkins LLP on

The SEC, by a 3-2 vote, has adopted new rules requiring companies to provide: ..current disclosure on Form 8-K within four business days of determining that a material cybersecurity incident has occurred; and ...more

Farella Braun + Martel LLP

Uber’s Former Chief Security Officer Found Guilty of Obstruction for Coverup of Data Breaches

On October 5, 2022, after a monthlong jury trial, former Uber Chief Information Security Officer Joseph Sullivan was found guilty of obstructing proceedings of the Federal Trade Commission (FTC) and misprision of a felony...more

StoneTurn

Shifting Cyber Landscape – Crisis Awareness as a Means to Prevent and Prepare

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Crises and uncertainty are inevitable forces in modern business, particularly in cyber and digital. General counsels and legal risk executives are well suited to lead preparedness and resiliency for future crises, uniting key...more

Wiley Rein LLP

New York State Department of Financial Services Proposes Updates to Cybersecurity Regulation

Wiley Rein LLP on

On July 29, 2022, the New York Department of Financial Services (DFS) released Draft Amendments to its Part 500 Cybersecurity Rules. These changes are open for a preliminary public comment until August 18, and then an...more

NAVEX

Bringing Together the People, Processes, and Tools for Cyber Risk Management

NAVEX on

Last month I wrote a post for this blog about the Securities and Exchange Commission’s proposals for more disclosure of cybersecurity issues. We reviewed some of the governance disclosures that boards might need to make, as...more

Perkins Coie

SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance

Perkins Coie on

As cybersecurity threats to the private and public sectors increase, the government has continued its efforts to enhance cybersecurity outside of government-controlled systems. On March 9, 2022, the U.S. Securities and...more

Fisher Phillips

New Federal Tools Can Help Private Sector Protect Trade Secrets From Cyberattacks – And May Soon Require Reporting

Fisher Phillips on

Cybersecurity was undoubtably on the forefront of the agenda for many organizations in 2020 – and 2021 should be no different. The rapid shift to remote work over the past year has led to an increased number of cybersecurity...more

Womble Bond Dickinson

Data Breaches and Educational Institutions

Womble Bond Dickinson on

Five things schools, colleges and universities can do this summer to address data privacy and protect against cybersecurity threats. Consider these five steps during your summer break to address the protection of...more

Jones Day

Deadline to Comply with New York's Cybersecurity Regulation Is Approaching

Jones Day on

For entities regulated by the New York Department of Financial Services, the deadline for complying with the new Cybersecurity Requirements for Financial Services Companies, 23 NYCRR Part 500, is Monday, August 28, 2017. To...more

Manatt, Phelps & Phillips, LLP

New York DFS Set to Regulate Cybersecurity

Why it matters - Stating that the New York Department of Financial Services believes cybersecurity to be one of the most critical issues facing the financial world today, the agency sent a letter to state and federal...more

Foley Hoag LLP

OCIE’s 2015 Cybersecurity Examination Initiative

Foley Hoag LLP on

Second Round of Cybersecurity Examinations to Begin - On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a...more

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