Privacy, Cyber, & Data Strategy Blog

On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help prepare for state cybersecurity exams and, ultimately, improve cybersecurity maturity. Developed by a multi-state team of cybersecurity examination experts, the Baseline Nonbank Cybersecurity Exam Program and the Enhanced Nonbank Cybersecurity Exam Program (the

  On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of Regulation S-P that arose in the context of a data disposal process, imposing a $35 million penalty. Specifically, the SEC

On September 7, 2022 the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) released an updated edition of its Cybersecurity Best Practices for the Safety of Modern Vehicles, the last edition of which was published in 2016. This most recent edition of this non-binding guidance leverages agency research, industry voluntary standards, and findings

On September 12, 2022, the Cybersecurity and Infrastructure Security Agency (CISA) issued a request for information (RFI) seeking input from stakeholders on the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). Signed by President Biden in March, CIRCIA requires CISA to develop and implement regulations requiring covered entities to report information about covered

On August 22, 2022, the Federal Trade Commission (FTC) published its advance notice of proposed rulemaking (ANPR) to request public comment on commercial surveillance and data security practices. The ANPR comes at the same time as Congress is considering the federal American Data Privacy and Protection Act (ADPPA). The FTC seeks public comment on a

According to recent media reports there have been several instances of blockchain bridges being hacked this year, including reports on August 2 that a bridge lost close to $200 million to upwards of 40 hackers who exploited a bug in its protocol, and reports in June that another bridge lost $100 million from hackers allegedly

Germany boasts one of the world’s largest, most sophisticated, and international economies. Companies doing business in Germany are thus an increasingly relevant target for cyberattacks. Germany‘s Federal Criminal Police Office (Bundeskriminalamt or BKA) is the federal law enforcement agency charged with investigating cybercrime, and for coordinating federal-state cooperation in cybercrime matters.  The BKA recently published

On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity theft, in violation of the SEC’s Identity Theft Red Flags Rule, or Regulation S-ID. Regulation S-ID requires registered financial institutions, broker dealers, and investment advisers