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Andrew Siegel

Andrew Siegel advises clients on advertising, data security, and privacy matters. Andrew represents clients in investigations by the Federal Trade Commission and State Attorneys General, advising clients on a variety of privacy and consumer protection matters, including marketing and claim substantiation issues. In addition, Andrew advises clients in investigating and responding to data security incidents and cyber-based attacks, including data breaches involving personal and other regulated data, advanced persistent threats, and state-sponsored attacks.

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On October 25, 2016, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory to financial institutions to (i) clarify reporting requirements under the Bank Secrecy Act (BSA) for filing Suspicious Activity Reports (SARs) on cyber-attacks and cyber-enabled crimes, (ii) note what information financial institutions should include in such reports, and (iii) encourage financial institutions to share information on cyber-attacks within the institution itself, with other banks, and with FinCEN and other regulators as appropriate.  The Advisory states that it is not designed to change current law.
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Continue Reading FinCEN Issues Advisory on Suspicious Activity Reporting Requirements for Cyber-attacks Under the Bank Secrecy Act