On July 27, 2022, the Securities and Exchange Commission (“SEC”) separately charged three financial institutions with violations of Rule 201 of Regulation S-ID (“Reg S-ID”), also known as the Identity…
On Friday, August 5, 2022 from 10:30 – 11:20 am EDT, Eric Dinallo, Luke Dembosky, Avi Gesser, Erez Liebermann, and Charu Chandrasekhar will be participating in the latest installment of…
On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Part 500 Cybersecurity Rules, which include a mandatory 24-hour notification for cyber ransom…
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…
On April 19, 2022, Kristin Snyder and Charu Chandrasekhar of Debevoise’s White Collar & Regulatory Defense Group, and Avi Gesser and HJ Brehmer of Debevoise’s Data Strategy & Security Group…
On March 9, 2022, the SEC released its newest series of proposed cybersecurity rules, this time for all public companies. Consistent with the proposed rules issued last month for investment…
On February 9, 2022, the SEC released its much-anticipated proposed rules relating to cybersecurity risk management, incident reporting, and disclosure for investment advisers and funds. Many of the proposals follow…
On January 24, 2022, SEC Chair Gary Gensler gave a speech on cybersecurity rulemaking to the Annual Securities Regulation Institute, outlining a number of key points he expects the SEC…
On October 13, the annual Securities and Exchange Commission Speaks seminar concluded with presentations from the Examination, Enforcement, and Investment Management divisions. As SEC regulated entities (including publicly traded companies,…
As part of our ongoing series on enforcement actions by the Securities and Exchange Commission (“SEC”) in data- and cybersecurity-related matters (here, here, and here), we have been closely tracking…