Andrew J. Ceresney – Debevoise Data Blog

Artificial Intelligence

AI Enforcement Starts with Washing: The SEC Charges its First AI Fraud Cases

By: Andrew J. Ceresney, Charu Chandrasekhar, Avi Gesser, Arian June, Robert B. Kaplan, Julie M. Riewe, Jeff Robins, Kristin Snyder, Jonathan R. Tuttle, James Amler, Phil Fortino, Matt Kelly, Anna Moody, Stephan J. Schlegelmilch, Gabriel Kohan and Corey Goldstein March 19, 2024

On March 18, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced settled charges against two investment advisers, Delphia (USA) Inc. (“Delphia”) and Global Predictions Inc. (“Global Predictions”) for making…

Artificial Intelligence

DOJ Announces Initiative to Combat AI-Assisted Crime

By: Helen V. Cantwell, Andrew J. Ceresney, Avi Gesser, Andrew M. Levine, David A. O'Neil, Winston M. Paes, Jane Shvets, Bruce Yannett and Douglas Zolkind February 16, 2024

On February 14, 2024, Deputy Attorney General Lisa O. Monaco announced an initiative within the U.S. Department of Justice to ramp up the detection and prosecution of crimes perpetrated through…

SEC

Hackers Turned Whistleblowers: SEC Cybersecurity Rules Weaponized Over Ransom Threat

By: Andrew J. Ceresney, Charu Chandrasekhar, Luke Dembosky, Avi Gesser, Matthew Kaplan, Erez Liebermann, Benjamin R. Pedersen, Steven J. Slutzky, Jonathan R. Tuttle, Matt Kelly and Kelly Donoghue November 20, 2023

On November 7, 2023, the profilic ransomware group AlphV (a/k/a “BlackCat”) reportedly breached software company MeridianLink’s information systems, exfiltrated data and demanded payment in exchange for not publicly releasing the…

Artificial Intelligence

SEC Proposes Rule to Eliminate or Neutralize Conflicts of Interest in the Use of “Predictive Data Analytics” Technologies

By: Andrew J. Ceresney, Charu Chandrasekhar, Avi Gesser, Robert B. Kaplan, Marc Ponchione, Julie M. Riewe, Jeff Robins, Kristin Snyder, Matt Kelly, Gary Murphy, Sheena Paul, Jarrett Lewis, Catherine Morrison and Mengyi Xu August 14, 2023

On July 26, 2023, the U.S. Securities and Exchange Commission (“SEC”) issued proposed rules (the “Proposed Rules”) that would require broker-dealers and investment advisers (collectively, “firms”) to evaluate their use…

SEC

The SEC’s New Risk Alert Warns about the Use of Alternative Data

By: Andrew J. Ceresney, Avi Gesser, Julie M. Riewe, Kristin Snyder, Jonathan R. Tuttle, Charu Chandrasekhar and Mengyi Xu May 2, 2022

On April 26, 2022, the Division of Examinations (“EXAMS”) of the Securities and Exchange Commission (the “SEC”) issued a Risk Alert titled “Investment Adviser MNPI Compliance Issues” (“Risk Alert”) on…