On July 26, the U.S. Securities and Exchange Commission adopted new rules regarding public companies’ reporting of (i) cybersecurity incidents, (ii) policies and procedures for identifying and managing cybersecurity risks and (iii) management and board roles in implementing cybersecurity policies and procedures. Read on for details about the new rules and recommended next steps for
The Securities and Exchange Commission continues to propose rules at a rapid pace. Three of the most recent proposed rules would significantly impact investment advisers by:
- Requiring documentation of registered investment adviser compliance reviews;
- Establishing cybersecurity risk management and reporting requirements for investment advisers, investment companies and business development companies;
- Updating and accelerating beneficial ownership
This week, the FBI, the Cybersecurity and Infrastructure Security Agency, and the Department of the Treasury released a joint advisory report on HIDDEN COBRA — the cyber threat North Korea poses to cryptocurrency — and provided mitigation recommendations for addressing this ongoing threat.
Read our full article on our Subject to Inquiry blog for highlights…
National Cybersecurity Awareness Month (NCSAM) is coming to a close, but diligent cybersecurity efforts must continue. In honor of another successful NCSAM, below we have gathered some of our most popular cybersecurity content you can use as a quick reference for all of your cyber-related interests.
On December 20, 2018, the Financial Industry Regulatory Authority (FINRA) released a report on cybersecurity practices for broker-dealers. Today’s post is the third in a series of summaries sharing essential, timely insight on how these practices may impact your business. Please click here for the first and second posts on cybersecurity practice impacts.
This post focuses on threats posed by insiders of the firm, which may be created by either deliberate, malicious conduct or by inadvertent mistakes. Both types of data breaches create significant risk to the firm and its customers. In the Report, FINRA notes that, while most higher revenue firms (95-99%) address insider threats as part of the program, only 66% of mid-level revenue firms address such risks. Its assessment comes from their review of firm responses to relevant inquiry areas in the 2017 and 2018 their Risk Control Assessment (RCA).
Continue Reading FINRA’s 2018 Report on Cybersecurity Practices – Insider Threats If Your Program Only Focuses on External Threats, You are Only Halfway There
On December 20, 2018, the Financial Industry Regulatory Authority (FINRA) released a report on cybersecurity practices for broker-dealers. Today’s post is the second in a series of summaries sharing essential, timely insight on how these practices impact your business. Please click here for the first post on cybersecurity practice impacts.
FINRA names “phishing” attacks as one of the most common cybersecurity threats raised by firms with the self-regulator. The goal of a phishing email is to manipulate the recipient into taking action. FINRA focuses on two types of phishing attacks in the report. The first is “spear phishing,” where the sender researches and targets the recipient(s) with a customized approach designed to get confidential information from the individual(s). The second is “whaling,” wherein the hacker sends targeted emails impersonating senior executives at the firm in order to set action in motion, typically wiring funds to specifically identified accounts. …
Continue Reading FINRA’s 2018 Report on Cybersecurity Practices – Preventing “Spear Phishing” and “Whaling” Attacks
On December 20, 2018, the Financial Industry Regulatory Authority (FINRA) released a report on cybersecurity practices for broker-dealers. This post is the first of a series of summaries sharing essential, timely insight on how these practices impact your business. The Report follows close on the heels of FINRA’s annual Report on Examination Findings issued Dec. 14, 2018. Now we know why Cybersecurity, a top regulatory and examination priority for FINRA in 2018, was not included in their examination findings report. Not surprising, albeit somewhat unusual, the importance of the topic and FINRA’s insights warranted a separate communication.
Continue Reading FINRA Issues 2018 Report on Selected Cybersecurity Practices
The U.S. Treasury recently released a report identifying improvements that would support nonbank financial institutions but also embrace innovation and technology. Among other things, the report recommends the creation of a national data breach notification standard and the development of effective national and international Fintech policies, including Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) efforts.…
This post originally appeared in our sister publication, Subject To Inquiry.
On May 21, the North American Securities Administrators Association (NASAA) announced a massive and coordinated series of enforcement actions by U.S. state and Canadian provincial regulators to combat fraudulent practices involving cryptocurrency-related investment products.
As cryptocurrencies have gained in popularity, companies have increasingly turned to a method known as an initial coin offering (ICO) to raise capital. ICOs, however, are ripe for potential fraud. As the Washington Post has explained, “consumers face higher risks of being misled at a time when the intense demand for bitcoin has prompted many retail investors to take extreme steps to gain exposure to the currency…”…
The 2018 Regular Session of the Virginia General Assembly recently concluded after considering approximately 3700 bills and resolutions during the 60-day session. Several privacy-related bills were on the legislative agenda, but few were enacted into law.
Tax Return Data
As highlighted in January, the General Assembly this year continued its efforts to address the…