As you know, the Securities and Exchange Commission (SEC) has been working on new cybersecurity disclosure rules for over a year. A few days ago, the SEC adopted the new rules on a vote of…
Compliance & Enforcement
With over a combined 25 years of business, legal, and technical experience, The Law Office of John J. Cooney, P.C. offers comprehensive legal strategies and solutions for businesses working seamlessly with management and any existing counsel in an efficient manner. John’s firm concentrates on General Counsel services, Pre-Litigation Investigation, Defense, and Compliance services, as well as the Cybersecurity arena.
In early May 2023, The Securities and Exchange Commission (SEC) announced a large enforcement action against broker dealers HSBC Securities Inc. and Scotia Capital Inc., which ultimately totaled $37.5 million in fines. This was a…
Earlier this year, the Financial Industry Regulatory Authority (“FINRA”) published its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”). The Report emphasized that FINRA believes “cybersecurity remains one of the principal operational…
Although the last few updates have concerned the New York Department of Financial Services (“DFS”) and its proposed amendments to its Cybersecurity Regulation, 23 NYCRR Part 500, it is important to remember that the Securities…
As discussed prior, in late 2022 the New York Department of Financial Services (“DFS”) published proposed amendments to its Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Amendments”). If the Proposed Amendments are adopted, they would…
The New York Department of Financial Services (“DFS”) recently released a proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Amendments”), which if adopted would go into effect sometime in 2023. The…
Firms should be aware of making potential admissions when assessing their cybersecurity risks, including when investigating an actual data breach. There have been a number of cases over the last several years that clearly illustrate…
The cybersecurity insurance market continues to evolve and there are some important developments for your consideration. In short, although cybersecurity insurance is an important component in your cybersecurity plan (e.g., mitigating costs), it is critical…
As you may remember, earlier this year the Securities and Exchange Commission (SEC) voted to propose cybersecurity rules and amendments related to disclosures, risk management and security incidents for registered investment advisers and registered investment…
Recently, the Division of Examinations of the Securities and Exchange Commission (the “SEC”) released its annual list of examination priorities for 2022. The SEC listed five “significant focus areas.” One of the five is entitled “Information…
Both the New York State Department of Financial Services (“DFS”) and the Securities and Exchange Commission (“SEC”) have warned financial entities that Russia’s invasion of Ukraine will likely result in an elevated number of cyber-attacks and…
As discussed in the prior update, the Securities and Exchange Commission (SEC), and specifically the Chair of the SEC, Gary Gensler, emphasized the SEC’s cybersecurity focus during his address at the 2022 Annual Securities Regulation…
As discussed in prior updates, the Securities and Exchange Commission (SEC) has increased its efforts with regard to cybersecurity. Towards that end, Chair of the SEC, Gary Gensler, discussed the SEC’s cybersecurity focus during his address at the…
In the summer of 2019, Capital One discovered that a hacker had accessed private data for more than 100 million Capital One customers, including data that was part of their credit card applications, such as…
In past posts, we discussed increased enforcement efforts by the Securities and Exchange Commission (SEC). The SEC’s focus should have come as no surprise given that in early 2021, the SEC highlighted information protection and cybersecurity as key…
In the last newsletter, we discussed the Securities and Exchange Commission (SEC) and its recent enforcement efforts. Specifically, how the SEC and the New York Department of Financial Services (DFS) have been pursuing entities for failure to…
In the last few posts, we discussed the NYS Department of Financial Services (“DFS”) and its enforcement efforts. Specifically, NY DFS has been going after entities for failure to report prior breaches. For example, DFS…
In the last newsletter, we discussed the NYS Department of Financial Services (“DFS”) recent efforts and its overall posture of ramping up enforcement. One of the important points that we noted was that the hefty multi-million…
In the last post, it was noted that the NYS Department of Financial Services (“DFS”) was ramping up enforcement of its Cybersecurity Regulation as evidenced by two recently announced multi-million dollar settlements. One of the…
The NYS Department of Financial Services (“DFS”) has recently announced two multi-million dollar settlements and has increased enforcement of its Cybersecurity Regulation. It is important to note that DFS has announced three enforcement actions since…
