Aguilar Discusses Cybersecurity and Enforcement

Commissioner Luis A. Aguilar delivered the morning keynote address last Thursday at the SINET Innovation Summit 2015 in New York. We continue to pay close attention when the Commissioner speaks as he has been a proponent on the subject of Cybersecurity, has contributed key guidance in previous speeches, and was the driving [...]

By |2018-01-22T11:55:16-05:00June 29th, 2015|Cyber Security|0 Comments

Wire Fraud and Executive Email – Are you Doing Enough?

Recent guidance from the Financial Services Information Sharing and Analysis Center (FS-ISAC) and the FBI suggests that Business Email Compromise (BEC) that leads to fraudulent wire transactions remains a significant threat to the industry. While the controls listed in the June 19th Fraud Alert were primarily directed at executives, Advisors and other [...]

By |2018-01-25T20:18:56-05:00June 25th, 2015|Cyber Security, Data Protection|0 Comments

Training – Are You Doing Enough To Meet Regulatory Expectations?

The Division of Investment Management’s recent cybersecurity guidance suggested that firms consider implementing training to provide guidance to officers and employees “concerning applicable threats and measures to prevent, detect, and respond to… threats and that monitor compliance with cybersecurity policies and procedures.” In addition, the Division suggested that firms “may wish to [...]

By |2018-01-25T21:28:17-05:00June 17th, 2015|Best Practices, Cyber Security|0 Comments

Is Risk Assessment Mandatory Via Recent SEC and FINRA Guidance?

This may be one of those cases where regulatory expectation is just as important as the written Rule.  The Division of Investment Management's April 28 guidance used the following language: “In the staff’s view, there are a number of measures that funds and advisers may wish to consider in addressing cybersecurity risk.”  [...]

By |2018-01-25T21:35:45-05:00June 10th, 2015|Best Practices, Cyber Security|0 Comments