Big businesses, especially those with a global footprint and operating in regulated sectors, are increasingly confronted with new and diverging cyber incident reporting requirements. A single incident—even a relatively minor…
On Tuesday, March 21, 2023, Julie Riewe, Kristin Snyder and Charu Chandrasekhar from our White Collar & Regulatory Defense Group, Jeff Robins from our Banking Group, and Avi Gesser and…
On March 15, 2023, the U.S. Securities and Exchange Commission (the “SEC”) released a suite of proposed new rules (the “Proposed Rules”) that include: Proposed new cybersecurity rules for broker-dealers,…
In February 2022, the SEC proposed its first-ever cybersecurity rules for registered investment advisers (“RIAs”) (including RIAs to private funds) and Funds (which include registered investment companies (“RICs”) and closed-end…
On March 2 and 3, 2023, the U.S. Department of Justice (“DOJ”) announced several updates to its corporate enforcement policies, in significant part formalizing recent pronouncements about corporate compliance programs.…
On January 10, 2023, the Financial Industry Regulatory Authority (“FINRA”) published its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”), which is intended to provide member firms…
On December 5, 2022, the Securities and Exchange Commission (the “SEC”) Division of Examinations (“EXAMS”) published a Risk Alert providing observations from recent examinations relating to investment adviser and broker-dealers’…
On September 20, 2022, the SEC announced settled charges and the imposition of a $35 million penalty against a dually registered investment adviser and broker-dealer (the “Firm”) for violations of Regulation…
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 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…