To gain insight into where the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) have been focusing their oversight and what their priorities will be in 2020, look no further than their recent words and deeds. A common thread running through the recent public statements and enforcement activity of both agencies is a commitment to maximizing the resources at their disposal to expedite resolutions, whether by leveraging technology, deploying multi-pronged approaches, engaging in industry outreach, or coordinating with fellow regulators.
Continue Reading Regulatory Moves Show Financial Watchdogs Working Smarter, if Not Harder

“If our country is to successfully defend our right to live the American way, it needs every one of you, and requires you in the best possible condition. Any [company] who willfully, or through neglect fails to maintain [their systems] in this condition is a ‘shirker’ who is throwing an extra burden on his comrades by requiring them to do his work as well as their own.”

It’s kind of apropos how easily you can adapt this introduction to a 1940s War Department venereal disease training film into a lesson addressing the 21st Century problems of cyberattacks and malware.  After all, certain computer attacks are called “virus” for a reason, businesses often find themselves in a virtual “war” with hackers and nation states on digital shores all around the world, and, perhaps most telling, the sordid details of both are things we really don’t like to discuss in “open and polite society.”  (I’ll stop there so as not to offend, but the list can go on.) So it comes as no surprise that it is the Department of Defense that is pulling back the curtain to openly address cyber-hygiene and, with the recent update and “open release” of the DoD Cybersecurity Discipline Implementation Plan, providing federal contractors and commercial companies alike with insight on the computer security prophylactics the Department is directing its units use.
Continue Reading DoD Reveals its Cybersecurity Discipline Implementation Plan (or How 1940s War Department VD Training Can Help Your 21st Century Cyber Hygiene)