News & Analysis as of

Policies and Procedures Risk Management Incident Response Plans

Mitratech Holdings, Inc

People and Policy: Building Compliance and Ethics into Your Company’s DNA

It’s not enough to have the right policies in place — you have to embed those policies into the fabric of your organization. In today’s fast-paced and interconnected business world, ensuring compliance and building an...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

Baker Donelson

Top Privacy and Cybersecurity Issues to Track In 2024

Baker Donelson on

In recognition of International Privacy Day on January 28, we wanted to share some insights on the top privacy and cybersecurity issues for the new year. Data privacy and cybersecurity will continue to be one of the most...more

WilmerHale

NYDFS Finalizes Amendments to Cybersecurity Regulations

WilmerHale on

On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

Eversheds Sutherland (US) LLP

New York Raises the Bar Again: Revised Cybersecurity Requirements for Financial Services Companies Finalized

On November 1, 2023, the New York Department of Financial Services (NY DFS) published its highly anticipated final amendments to its influential cybersecurity requirements for financial services companies (Part 500)....more

Health Care Compliance Association (HCCA)

Privacy Briefs: October 2023

Report on Patient Privacy 23, no. 10 (October, 2023) Kaiser Foundation Health Plan Inc. and Kaiser Foundation Hospitals will pay California $49 million to resolve allegations that they unlawfully disposed of hazardous waste,...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Adopts Final Cybersecurity Rules for Public Companies

In a narrow 3-2 decision on July 26, the SEC adopted its final rule concerning cybersecurity risk management, strategy, governance, and incident disclosure (the “Final Rule”).  Below we highlight some of the principal changes...more

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

Jenner & Block on

Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

Paul Hastings LLP

The Board is Set: Preparing for the SEC’s Upcoming Cybersecurity Rules

Paul Hastings LLP on

It has been a full year since the initial comment period closed on the Securities and Exchange Commission’s (“SEC”) proposed rule on cybersecurity disclosure, governance, and risk management for public companies (the...more

Dechert LLP

SEC Proposes New Cybersecurity Risk Management Rule for Various Market Entities

Dechert LLP on

At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted three to two to propose a new rule, form and amendments (together, “Proposed Rule”) and published an accompanying release (“Release”)...more

Sheppard Mullin Richter & Hampton LLP

Ethics & Compliance: Let’s Talk About Cybersecurity

Over the past few months, the OIG shorts series focused on structuring and implementing a comprehensive and effective ethics and compliance program. Many times, this requires a mindset shift from a checking-the-box mentality...more

J.S. Held

Cyber Security & Business Interruption: Foundations for Prevention and Mitigation

J.S. Held on

The modern security ecosystem is diverse and ever-changing, a place where cyber risk is top of mind for leaders at all levels, and threats to information / data security and privacy evolve at the speed of the technical...more

Paul Hastings LLP

SEC Proposed Cybersecurity Rules – What They Are and What Our Clients Should be Doing Now

Paul Hastings LLP on

What are the new rules? Earlier this year, the Securities and Exchange Commission (“SEC”) published a new set of proposed cybersecurity disclosure rules for public companies. The proposed rules would significantly increase...more

StoneTurn

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

StoneTurn on

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

Pillsbury Winthrop Shaw Pittman LLP

Increasing Markets for Sports Betting Could Lead to Cybersecurity and Data Privacy Risks for Companies and Consumers

Providers of sports betting services must ensure that their cybersecurity protocols and data privacy policies adequately protect their systems and users. Since the Supreme Court struck down the federal ban on sports gambling...more

Orrick, Herrington & Sutcliffe LLP

Tips for Surviving the First 24 to 48 Hours After an Incident

As cybersecurity incidents become increasingly complex, your initial response to a potential cybersecurity crisis matters. The decisions that you make in the first 24 to 48 hours of a potential cybersecurity incident can have...more

NAVEX

The Complicated Tango of Compliance & Cybersecurity

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A ransomware attack is no company’s idea of a good time, but I do sense one positive development emerging from the epidemic of attacks we’ve witnessed this year: Boards and senior management agree that they must move beyond a...more

NAVEX

4 Steps for Risk-Based Back-to-Work Planning

NAVEX on

Navigating COVID-19 (and beyond) requires organizational resiliency, flexibility, and innovation when returning to a new standard in business operations. HR and risk professionals need to understand how to overcome the legal,...more

Seyfarth Shaw LLP

Recipe for Action for Restaurants and Food Service Chains to Address Coronavirus Concerns

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Seyfarth Synopsis: As restaurant and hospitality consumers rethink their dining experiences, increased concerns are coming from food service providers about how to ensure food safety, reassure patrons, and address issues...more

Kramer Levin Naftalis & Frankel LLP

Cybersecurity: the SEC Provides Guidance on Well-Known and Emerging Best Practices

At the end of January, the U.S. Securities and Exchange’s Office of Compliance Inspections and Examinations (OCIE) released its “Observations on Cybersecurity and Resiliency Practices” (Observations)....more

Bracewell LLP

SEC Examiners Release Cyber Observations: What You Need To Know

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On January 27, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its most recent Cybersecurity and Resiliency Observations. This report highlights specific practices that have been, and can be...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: Cybervigilance and Cyber-resiliency

Mark Lanterman, Chief Technology Officer of Computer Forensic Services lives technology at its most terrifying, helping organizations manage the risks of the IT we all use constantly. Recently he authored an article...more

Mitratech Holdings, Inc

Global Voices: Incident Management – Key Component of a Defensible Compliance Program

As you may recall, the United States Federal Sentencing Guidelines for Organizations (FSGO) has provided the basis for American courts to impose harsh penalties upon organizations whose employees or agents have violated...more

NAVEX

When Managing Whistleblower and Retaliation Risk, Tools are Important – Processes and People are Critical

NAVEX on

One collection of terms I hear a lot is “tools, processes and people.” All three need to be successfully deployed to make a compliance program run properly while also creating an organizational culture that supports...more

Stinson - Corporate & Securities Law Blog

The New York State Department of Financial Services Proposes Robust Cybersecurity Rules

On September 13, 2016, the New York State Department of Financial Services (DFS) proposed new rules that would require certain “Covered Entities” to establish and implement cybersecurity programs designed to protect nonpublic...more

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