Tag Archives: FinCen

NFA’s Amended Cybersecurity Guidance Includes New Incident Reporting Requirement

Photo of Jonathan A. FormanBy Jonathan A. Forman on Posted in Cybersecurity, Incident Response
Following other regulators, the National Futures Association (NFA) recently amended its cybersecurity guidance to, among other things, impose a new cybersecurity incident reporting requirement on members. Cybersecurity Incident Reporting. According to the amended guidance, members will be required to report to NFA any cybersecurity incident related to the member’s commodity interest business that resulted in … Continue Reading

Will the proposed “Countering Russian Hostilities Act” stop Russian cyberattacks?

By Randal L. Gainer and Carol Van Cleef on Posted in International Privacy Law
On Jan. 10, 2017, a bipartisan group of five Republican and five Democratic senators announced their support for the Countering Russian Hostilities Act of 2017. Lindsey Graham, one of the senators who announced the proposed legislation, told The Wall Street Journal that he is confident the bill will get overwhelming support.[1] One reporter agreed, stating … Continue Reading

Digital Currency Exchange Customers Targeted in IRS Information-Gathering Sweep

Photo of Jeffrey H. ParavanoBy Carol Van Cleef, Jeffrey H. Paravano and Jay R. Nanavati on Posted in Financial Privacy
Coinbase, one of the largest digital currency exchange companies in the world, will likely be asked to provide the Internal Revenue Service (IRS) with transactional data and other information on all U.S. customers who used its services over a three-year period. Using what is known as a “John Doe” summons, the IRS has formally requested … Continue Reading

Deeper Dive: Plan for Regulatory Scrutiny in Financial Services Data Security Incidents

Photo of Gerald J. FergusonBy Gerald J. Ferguson and Jenna N. Felz on Posted in Cybersecurity, Financial Privacy
Financial services industry companies were involved in 18% of the over 300 data security incidents we helped manage in 2015, and reported in our 2016 BakerHostetler Data Security Incident Response Report (the “Report”). After healthcare, the financial services industry was the second most affected industry according to the data we reported. It is not surprising … Continue Reading
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