In a statement issued on Wednesday, September 20th, the U.S. Securities and Exchange Commission (SEC) revealed that it was investigating a 2016 data breach of its Electronic Data Gathering, Analysis, and Retrieval (EDGAR) database. The SEC does not believe that personally identifiable information was exposed, but the investigation is still ongoing and raises questions regarding government agencies’ obligations to protect sensitive information, and the potential litigation challenges facing individuals who are impacted by hacks of … Continue Reading
We have issued a memo on recent proposed U.S. federal banking regulations that could significantly expand the existing cybersecurity regulatory framework for covered financial institutions. The Enhanced Standards intend to strengthen cyberattack preventative measures and post-attack responses.
On October 25, 2016 FinCEN issued an advisory and FAQs to financial institutions regarding their Suspicious Activity Report (SAR) obligations with respect to cyber-events, cyber-enabled crime, and cyber-related information as those terms are defined. The FAQs supersede previous FAQs issued in 2001. The advisory and FAQ also discuss collaboration between in-house BSA/AML teams (e.g., noting that the BSA/AML teams need not have personnel devoted … Continue Reading