SEC Issues $1 Million Identity Theft Rule Fine

By Liisa Thomas and Amber Thomson on October 22, 2018 Posted in Privacy, SEC

The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as the Safeguards Rule). According to the SEC, Voya had failed to implement a written identity theft program as required of broker-dealers and … Continue Reading

You Might Be an Inside Trader If: Insider Trading and Data Breaches Part II

By Kari Rollins and Sarah Aberg on June 21, 2018 Posted in Data Breach, Privacy Litigation, SEC

As we wrote yesterday, the CIO of Equifax is currently facing civil and criminal liability following trading he made after his employer suffered a major cybersecurity breach. As we indicated in our prior blog post, the SEC has filed a complaint alleging liability because he independently figured out that his employer was the victim of a … Continue Reading

You Might Be an Inside Trader If…: Insider Trading and Breaches Part I

By Kari Rollins and Sarah Aberg on June 20, 2018 Posted in Data Breach, Privacy Litigation, SEC

Earlier this year, the SEC released cybersecurity guidance addressing, among other things, the risk of insider trading in the event of a data breach. The insider trading risk includes risk that the intruder will trade on stolen information and risk that insiders will trade on the knowledge of the breach itself. In this manner, the … Continue Reading