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SEC To Focus on Cybersecurity in 2019

For the fourth year running, the Securities and Exchange Commission’s Office continues to list cybersecurity as one of the top enforcement priorities for 2019. As it relates to cybersecurity, the SEC will be focusing on ensuring companies have proper configuration of network storage devices, robust information security governance, and established policies and procedures specific to protecting retail investors’ trading information and preventing cyber intrusions into retail brokerage accounts. The SEC also wants to see that companies manage both their own systems (including legacy systems), as well as maintaining adequate oversight of the practices of their partners and affiliates.

The SEC has also articulated concern and focus regarding the cybersecurity practices of investment advisors. In particular, the SEC indicated it will review cybersecurity policies of investment advisors, with a focus on those with multiple branch offices or that have recently merged with other advisers. Investment advisors will need to demonstrate suitable governance and risk assessment of cyber risks, including incident response plans; robust controls and procedures around access to systems containing customer information; data preservation procedures; vendor management guidelines specific to cyber-related vendors; and cybersecurity training.

Putting it Into Practice: The SEC continues to pay significant attention and scrutiny to the cybersecurity practices and preparedness of market participants and registered entities. Companies should keep this in mind as they prioritize and fund their security efforts throughout 2019.

Copyright © 2020, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume IX, Number 86

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About this Author

Kari Rollins Intellectual Property Lawyer Sheppard
Partner

Kari M. Rollins is a partner in the Intellectual Property Practice Group in the firm's New York office.

Areas of Practice

Ms. Rollins focuses her practice on privacy and complex commercial litigation matters. She has successfully represented clients in the financial services, audit and accounting, food services, retail, and fashion industries before state and federal courts, as well as in front of state attorneys general, federal regulators, and U.S. and international commercial arbitration forums....

212.634.3077
Sarah Aberg Government Contracts Attorney Sheppard Mullin Law Firm New York
Special Counsel

Sarah Aberg is special counsel in the White Collar Defense and Corporate Investigations Group in the firm's New York office.

Areas of Practice

Sarah's practice encompasses litigation, internal investigations and white collar defense, with a focus on financial services and securities. She has conducted multiple criminal trials and numerous internal investigations into a wide variety of allegations, including mail and wire fraud, mortgage fraud, insider trading, market manipulation, money laundering, terrorist financing, cybercrimes, and data privacy violations.  Sarah’s regulatory practice encompasses market regulation, foreign registration and disclosure requirements, supervisory procedures, and sales practices.  Sarah represents corporations, financial services companies, and associated individuals in connection with investigations and regulatory matters before the U.S. Department of Justice, the Securities and Exchange Commission, the Commodity Futures Trading Commission, FINRA, the New York Stock Exchange, the New York State Department of Financial Services, and the New York Attorney General’s Office.

212-634-3091