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Effective information security is no longer just dependent on an organisation’s own internal cybersecurity controls. The UK Information Commissioner’s Office (ICO) highlights that third-party service providers are processing...more
Most people know what a deepfake is but have not put much thought into how it could affect business operations. Deepfakes are videos, pictures, or audio that have been convincingly manipulated to misrepresent a person saying...more
We recently dove into what vendor risk and vendor risk management entails. Once you understand that this is the risk that results from vendors, it’s simple to extend this and establish that vendor risk assessment (VRA), or...more
Vendor risk management (VRM), or third-party risk management, is the management, monitoring, and evaluation of risks that result from third-party vendors and suppliers of products and services. It’s a crucial initiative...more
The Consumer Financial Protection Bureau's Compliance Bulletin and Policy Guidance; 2016-02, Service Providers addresses the CFPB's expectation that companies oversee their business relationships with service providers in a...more
Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more
This client alert will briefly outline key upcoming deadlines under the New York State Department of Financial Services (DFS) Cybersecurity Regulation (the “Regulation”). These include annual filing deadlines coming up in...more
The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more
Risk Management is a constant theme for top management as it might make the difference between a successful move and failure. It implies identification, assessment and prioritization of risks....more
New privacy torts have recently emerged in certain Canadian jurisdictions, including intrusion upon seclusion and publicity given to private life. Intrusion upon seclusion allows a plaintiff to sue if (1) a person has...more
The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more
On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more
Tennessee has joined other states in formally approving lawyers’ cloud-storage of client-confidential data. The Board of Professional Responsibility (“BOPR”) held that lawyers ethically may use cloud storage for...more
This week the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced a second-round of cybersecurity examinations, continuing its initiatives on the issue. The move follows the SEC’s: March 2014 roundtable...more
For years, banks have relied on third party vendors to provide specialized products or services, or have used outsourcing as a way to reduce internal operating costs. In the wake of the financial crisis, however, regulators...more