The recent convictions of two traders for using hacked press releases and the settlement of SEC insider trading charges against a former Equifax manager highlight the significant insider trading risks companies face when dealing with a cyber event.  These risks come in two forms.

First, there is the risk that … Read More

Cyber threats remain a key operational concern for banks, which are otherwise experiencing “near-historic” capital and liquidity highs and improved returns on equity, according to the Office of the Comptroller of the Currency (the “OCC”).  The regulator published its Fall 2017 Semiannual Risk Perspective on January 18th, stating that “operational … Read More

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.

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 FinCEN Issues Advisory and FAQs on Cyber-Events and Cyber-Enabled Crime (10/27)

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 Read More

We have issued a memo on recent proposed cybersecurity regulations by the New York State Department of Financial Services that would be more stringent than existing federal requirements for certain financial entities. The memo highlights similarities and differences between the proposed regulations and federal regulations and guidance.

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