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
On July 24, 2019, both the Federal Trade Commission (FTC) and the Securities and Exchange Commission (SEC) announced landmark settlements with Facebook. The agreements were significant not only because of the hefty fines...more
Just when you thought the hazards of cyberfraud couldn’t get worse, the SEC recently issued a Report of Investigation (more on that later) stating that nine recent corporate victims of cyberfraud may have compounded their...more
In an October 16, 2018 investigation report, the Securities and Exchange Commission found that nine companies that suffered Business Email Compromise, or BEC, had insufficient internal controls to prevent such attacks....more
On February 21, 2018, the Securities and Exchange Commission issued an interpretive release1 providing important guidance to certain registrants on cybersecurity disclosure. Coming on the heels of dozens of high-profile...more
In this issue: - Navigating Public Company Cybersecurity Obligations: Advising Boards and Disclosing to Investors - FTC Updates School-Related COPPA Guidance - Status Update on the EU Data Protection...more