On October 1, 2020, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to companies that pay a ransom in the wake of a cyberattack. Specifically, the advisory warned that...more
On September 15, 2020, the New York Attorney General’s Office (NYAG) announced a settlement with Dunkin’ Brands, Inc. (Dunkin) in connection with a September 2019 lawsuit brought by the NYAG against Dunkin for alleged...more
On September 15, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert highlighting the recent uptick in “credential stuffing” cyber-attacks against SEC-registered investment advisors...more
9/18/2020
/ Broker-Dealer ,
Compliance ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Protection ,
Identity Theft ,
Investment Adviser ,
Popular ,
Risk Alert ,
Securities and Exchange Commission (SEC)
In July 2020, the New York State Department of Financial Services (NYDFS) filed the first enforcement action under the new NYDFS Cybersecurity Regulation, 23 NYCRR Part 500 (Part 500), against First American Title Insurance...more
Business Email Compromise (BEC) scams have become increasingly commonplace and financially destructive. According to the Federal Bureau of Investigation (FBI), 2019 was the worst year on record for BEC scams — both in terms...more
On May 26, 2020, a United States Magistrate Judge in the Eastern District of Virginia ordered Capital One to disclose to class action plaintiffs a report prepared by Mandiant, a cyber forensics firm, for Capital One’s outside...more
On April 13, 2020, the New York Department of Financial Services (NYDFS) issued new guidance to all New York State Regulated Entities to highlight “a significant increase in cybercrime” related to the COVID-19 epidemic....more
As COVID-19 has prompted a massive shift by organizations to the implementation and use of remote working solutions for their employees, there has been an unfortunate, but not surprising, corresponding rise in malicious...more
As the COVID-19 pandemic continues to demand the attention of corporate leaders and the public at large, businesses have likely had little time to get up to speed on New York’s new data breach notification law, the Stop Hacks...more
The spread of COVID-19 has prompted an enormous shift by organizations to the use and implementation of remote working solutions for a wide range and number of employees. Unfortunately – but perhaps not surprisingly – this...more
The SEC, through its Office of Compliance Inspections and Examinations (“OCIE”), recently issued its most detailed cyber guidance to date. OCIE had previously issued several cybersecurity risk alerts over the past few years....more
2/13/2020
/ Corporate Issuers ,
Cybersecurity ,
Data Management ,
Incident Response Plans ,
Internal Controls ,
Investment Adviser ,
New Guidance ,
OCIE ,
Risk Alert ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Security and Privacy Controls ,
Third-Party Service Provider
On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more
12/16/2019
/ Cooperation ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Government Investigations ,
Internal Investigations ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Voluntary Disclosure
On July 16, 2019, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an “Updated Advisory on Email Compromise Fraud Schemes Targeting Vulnerable Business Processes” (the “Advisory”). The...more
On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more
5/29/2019
/ Broker-Dealer ,
Cloud Storage ,
Customer Information ,
Cyber Threats ,
Cybersecurity ,
Data Protection ,
Data Security ,
Data Storage Providers ,
Identity Theft ,
Identity Theft Red Flags Rule ,
Investment Adviser ,
OCIE ,
Policies and Procedures ,
Popular ,
Regulation S-ID ,
Regulation S-P ,
Regulatory Requirements ,
Risk Alert ,
Safeguards Rule ,
Securities and Exchange Commission (SEC) ,
Third-Party Service Provider ,
Vendors