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The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more
On March 24 2025, the European Commission (EC) adopted the final draft Delegated Regulation setting out Regulatory Technical Standards (RTS) for subcontracting ICT services supporting critical or important functions under the...more
EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as...more
The European Union’s Digital Operational Resilience Act (DORA) came into effect on January 17, 2025. DORA aims to harmonise rules concerning the provision of information and communication technology (ICT) services to...more
After a two-year implementation period, the EU Digital Operational Resilience Act (DORA) takes effect on 17 January 2025. DORA is part of the EU’s Digital Finance Package and aims to strengthen the financial sector’s...more
The EU Digital Operational Resilience Act (“DORA”) is due to apply from 17 January 2025. It is designed to ensure regulated financial entities can withstand and recover from technology issues such as cyber events and...more
The Digital Operational Resilience Act 2022/2554 (DORA) is a European regulation that will come into force on January 17, 2025. The regulation aims to strengthen the digital operational resilience of the financial sector...more
On October 16, 2024, the New York State Department of Financial Services (NYDFS) released guidance highlighting the cybersecurity risks associated with artificial intelligence (AI) and how covered entities regulated by NYDFS...more
The European Commission’s adoption on 23 October 2024 of the two regulations (Regulations) supplementing the [the Regulation on digital operational resilience for the financial sector Publications Office (europa.eu)] (DORA)...more
The deadline is fast approaching for in-scope financial entities and their ICT service providers to conform to the EU’s new digital operational resilience regulation. With effect from 17 January 2025, a broad range of EU...more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management...more
The publication by the Joint Committee of the European Supervisory Authorities (ESAs) on (a) 17 July 2024 of the second batch of implementing materials and (b) 26 July 2024 of the sub-contracting of information and...more
The Australian Prudential Regulation Authority (APRA) released Prudential Standard CPS 230 in March 2017. At a glance, the regulation aims to strengthen the cybersecurity resilience and operational risk management of the...more
On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more
Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more
On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more
Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...more
The financial sector is greatly dependent on information and communication technologies (ICT). The importance of ensuring remote access to financial services increased to an even greater extent during the COVID-19 pandemic,...more
Vendor Risk Management (VRM) featured heavily at the recent Mitratech Interact 2020 online conference. That’s not surprising, considering the rising concerns about the risks posed by vendor and supplier networks – and how...more
In December 2019, we published a blog post introducing open banking; here, we provide an update for 2020. To briefly summarize, open banking comprises a set of rules which permit third-party providers (TPPs) of financial...more
Vendor management is a complex task, yet a necessary undertaking for any organization dealing with third parties. ...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more
In an Industry Letter, the New York State Department of Financial Services (NYDFS) is requesting assurance that New York State regulated institutions have preparedness plans in place to address operational risk, and it is...more