On March 24, 2017, Treasury Secretary Steven Mnuchin gave a speech in which he identified cybersecurity as his primary concern regarding the financial sector.  Secretary Mnuchin said in his remarks that ensuring a “safe and sound financial sector” requires cooperation and investment among the various financial regulators.  The Secretary emphasized that he wants regulatory agencies

On February 6, the FTC, along with the State of New Jersey, announced a settlement with TV-maker VIZIO related to VIZIO’s alleged data collection practices on millions of its ‘smart,’ network-connected TVs. According to the complaint, VIZIO collected information on consumers which it then shared with third parties, without sufficiently disclosing the data collection

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.

Continue Reading FinCEN Issues Advisory on Suspicious Activity Reporting Requirements for Cyber-attacks Under the Bank Secrecy Act

On October 19, 2016, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation released a joint Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on enhanced cybersecurity standards that would apply to certain large, interconnected financial entities as well as