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A.J. Dhaliwal

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A.J. is a special counsel in the Finance and Bankruptcy Practice Group in the firm's Washington, D.C. office.

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The FTC recently announced a final rule updating its GLBA Safeguards Rule to “strengthen the data security safeguards” of consumer financial information. The FTC reported that it was making these changes in response to widespread data breaches and cyberattacks.  As we reported in our sister blog, the changes will mean that a broad range of non-banking financial institutions may need to make updates to their data security policies and procedures. The new requirements go into effect in November 2022.
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Continue Reading Non-Banking Institutions Will Want to Review Security Measures in Light of Update to Safeguards Rule

The European Securities and Markets Authority (ESMA), the EU’s securities markets regulator, recently announced that it fined UnaVista Limited, a UK-based trade repository, €238,500 ($280,000) for eight breaches of the European Market Infrastructure Regulation (EMIR).  The EMIR includes rules regulating the conduct of trade repositories, and in conjunction with its role as the supervisor of trade repositories under EMIR, ESMA is empowered to file enforcement actions in response to infringements of EMIR by trade repositories.
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Continue Reading European Securities Watchdog Fine Highlights Importance of Data Integrity and Regulatory Access

The New York State Department of Financial Services recently announced new guidance addressing ransomware attacks, and highlighting cybersecurity measures to significantly reduce the risk of an attack.  The guidance comes as ransomware rates have been increasing, and builds on the post SolarWinds guidance from NYDFS about supply chain management. It was released just prior to the most recent large attack, namely the July 2nd supply-chain ransomware attack centered on the U.S. information technology firm Kaseya.
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Continue Reading NYDFS Issues Ransomware Guidance