Due Diligence – How CCOs Can Slay the Two-Headed Dragon
Due Diligence For Your Vendors And Your Firm Bolstering fortifications around vendors is a critical area of any firm's cybersecurity program. At the same time, investment advisers, investment companies, and broker-dealers, as vendors themselves, are subject to increasing scrutiny by their institutional investors. Both the SEC and FINRA have recognized the [...]
Enlist Your Customers to Secure Your Firm
A compliance officer knows that he or she must consider third party risks in any assessment. As the threat landscape has changed, third-party risk has become more and more focused on information security. The need for initial and ongoing due diligence of critical third parties is understood and should be part [...]
Cyber Insurance – Transferring the Risk, Not the Responsibility
A first glance, Cyber Liability Insurance seems like a panacea for the harried financial services firm looking to shore up its defenses from nefarious hackers. However, if you don’t have your cybersecurity house in order, you can find yourself doubling down on the losing end: paying for a policy that doesn’t [...]
5 Basic Exam Questions of The Future: Are You Prepared?
Regulatory guidance on cybersecurity shows little sign of abating and additional governmental legislation continues to complicate every CCO’s day. With the regulatory landscape continuing to grow more complex, we pause to ask the question: Have you thought about your next presence exam? Preparing today can be the most important step you [...]
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 [...]
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 [...]