Photo of Reuben Grinberg

Mr. Grinberg is an associate in Davis Polk’s Financial Institutions Group. His practice focuses on advising financial institutions and industry groups on a wide range of bank regulatory and cybersecurity matters. He also provides strategic, transactional and regulatory advice to a wide array of both established and emerging participants in the FinTech space, including the regulatory treatment of virtual currencies and blockchain.

Companies and law enforcement are increasingly turning to white hat hackers for help.  The FBI apparently paid consultants over $1,000,000 to unlock an iPhone used by one of the shooters in the San Bernardino attacks, and companies such as Microsoft, Uber, Facebook, and Google are paying hackers tens of thousands
Continue Reading

During congressional hearings earlier this month, senators grilled Richard Smith, the former Equifax CEO, on the company’s reporting structure for cybersecurity; specifically, on the appropriateness of Equifax’s CISO reporting to the general counsel.  This has caused several companies to question their own reporting structures for cybersecurity issues.  So what is
Continue Reading

Earlier this month, HBO disclosed that it is the latest victim of cyber breach extortion, which involves criminals hacking into a company’s computer system, extracting sensitive information (e.g., emails of executives) or valuable intellectual property (e.g., unreleased television scripts or episodes), and then threatening to make the information public if
Continue Reading

With about a month to go until the first set of NYDFS’s cybersecurity rules go into effect (on August 28, 2017), we are proud to announce the formal launch of the Davis Polk Cyber Blog.  The blog will help you keep pace with industry best practices and be aware
Continue Reading

In a Risk Perspective released on July 7, 2017, the Office of the Comptroller of the Currency (“OCC”) emphasized the need for institutions to be cyber resilient – i.e., be able to respond to cyber attacks by managing various risks.  Acting Comptroller Keith Noreika noted in a speech on the
Continue Reading