New York Finalizes Cybersecurity Regulations for Financial Institutions

On February 16, the New York State Department of Financial Services (NYDFS) issued cybersecurity regulations for banks, insurance companies and other financial institutions subject to NYDFS jurisdiction.

Treasury Department Imposes New Sanctions Against Iran and Clarifies Russia Cyber Sanctions

Last week saw the first action by the Treasury Department's Office of Foreign Assets Control under the new administration, including two notable developments.

President Obama Sanctions Russia Over Malicious Cyber-Enabled Activities

President Obama amended a previously-issued executive order designed to address cyber-enabled activities yesterday in response to “Russia's cyber activities [that] were intended to influence the election, erode faith in US democratic institutions, sow doubt about the integrity of our electoral process, and undermine confidence in the institutions of the US government.”

Presidential Cybersecurity Commission Issues Ambitious Policy Roadmap for Next Administration

On December 1, the nonpartisan Commission on Enhancing National Cybersecurity, established pursuant to an Executive Order in February, issued its report, outlining more than 50 recommendations for the next Administration.

FERC Enforcement Office Remains Focused on Market Manipulation and Compliance Programs

This month, the Office of Enforcement of the Federal Energy Regulatory Commission released its tenth Annual Report on Enforcement. The report provides FY2016 statistics on the investigative and enforcement activities conducted by OE's four divisions—Investigations, Audits and Accounting, Energy Market Oversight, and Analytics and Surveillance.

Banking Regulators Release Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

The agencies are considering establishing two tiers of enhanced standards—basic enhanced standards for all covered firms and even more stringent enhanced standards for systems that are "sector-critical."

Civil Penalties Set to Increase Significantly, Many Present Retroactivity Concerns

Over the past several months, many federal agencies have adopted rules significantly increasing the maximum civil monetary penalties (CMPs) they can potentially impose. The increased penalty amounts were adopted in response to recent legislation from Congress requiring that federal agencies make adjustments to “catch up” with inflation.

WilmerHale Partnership with Leading FinTech Accelerator Culminates in First NY Demo Day

Ten groups of financial technology entrepreneurs presented their innovations to an audience of more than 500 investors, industry experts and journalists.

NYDFS Issues Final Rule Requiring Certification of Compliance With AML Transaction Monitoring and Filtering Program Requirements

The New York Department of Financial Services recently finalized a regulation that mandates detailed elements of the anti-money laundering transaction monitoring and sanctions filtering programs of covered institutions. The rule, published on June 30, 2016, also requires directors or senior officers to certify their institutions' compliance with these new standards.

Civil Fines Jump Across Agencies Under Inflation Adjustment Act

Civil fines across federal agencies have recently been increased dramatically under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (2015 Act) (Sec. 701 of Public Law 114-74), with some more than doubling. Companies violating the Hart-Scott-Rodino (HSR) Improvements Act, the Securities and Exchange Act, or the Occupational Safety and Health Act (OSHA), among others, could soon face civil monetary penalties that are up to 150% higher than the existing levels. According to the Congressional Budget Office, the 2015 Act would increase the federal government's revenue by $1.3 billion over the next ten years.

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