GDPR: The Final Countdown and 11th Hour Checklist

“The right to be forgotten” may sound like the title of this year’s summer blockbuster sci-fi film, but for companies preparing for GDPR, the entertainment value of that phrase is dubious. It is, in fact, one of the core requirements of the EU’s forthcoming GDPR (General Data Protection Regulation), which will take effect on May […]

Continue Reading
FCA Regulatory Priorities for 2018

On April 9, 2018, the UK’s Financial Conduct Authority (FCA) published its Business Plan for 2018/19 which highlights the key priorities for this year. This year’s priorities reflect the resources the FCA needs to prepare for withdrawal from the European Union (EU). Brexit is a key priority for the FCA as it seeks a smooth […]

Continue Reading
GDPR and Rogue Whistleblowers – Who is the Data Processor?

Several organisations have considered the effect of GDPR in the context of whistle-blowing and the steps required to investigate claims, but what are the implications when a whistleblower doesn’t follow set procedures and decides to take matters into their own hands? Under GDPR the responsibilities of data processors has been expanded. Previously, the Data Protection […]

Continue Reading
Regulatory Update: Former Equifax CIO Charged with Insider Trading – Texting at the Center of the Charges

The text message from the former Equifax CIO was a red flag: “Sounds bad. We may be the one breached.” Federal prosecutors charged a former Equifax chief information officer (CIO) with insider trading, for selling nearly $1 million in company stock before the public disclosure of the Equifax data breach. The former CIO of a […]

Continue Reading
Regulatory Updates: Enforcement is Heating Up Across the Regulatory Landscape

Last month, the SEC and FINRA fined several firms for failure to establish reasonably designed supervision programs to ensure compliance with applicable securities laws and regulations. Individuals were also fined for failing to comply with securities laws and regulations pertaining to electronic communications. The SEC penalized a bank $3.7 million for failing to reasonably supervise […]

Continue Reading
SEC Reveals 2018 OCIE Exam Priorities

The Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) recently published its 2018 examination priorities letter. The priorities reflect certain practices and products the examiners believe may present potentially heightened risk to investors or the integrity of the U.S. capital markets. This year’s examination priorities are organized around five themes: (1) […]

Continue Reading
Regulatory Updates: Disciplinary Actions Against Firms and Individuals for Unauthorized Communication Channels

FINRA is increasing disciplinary actions against firms and individuals for failing to comply with recordkeeping and supervision rules. Last month, FINRA fined firms and individuals for using “unauthorized communication channels” including text messaging, IM, and personal emails. A brokerage firm was fined $290,000 for failing to establish a system of reasonable supervision, including adequate Written […]

Continue Reading
MiFID II is now in Effect, but will It Conflict with the Upcoming GDPR?

Thanks to the Markets in Financial Instruments Directive (MiFID II), which went into effect at the beginning of the year, banks and other highly regulated industries will be recording and archiving all communication made by phone, email, social media, unified communications, encrypted messaging and any other medium used to correspond with clients for at least […]

Continue Reading
The Conversation is Shifting: A Changing Workplace and Untethered Workforce

It’s no secret that office life is changing. Across industries, the silos that technology helped create are being torn down to increase productivity and knowledge sharing. This transition is clearly for the better, but many organizations in regulated industries are struggling to have their compliance programs keep pace with the demand for more mobile-centric communication […]

Continue Reading