Tag: DFS

Categories
FCPA Compliance Report

Eric Young on the Fed and DFS Components of the Goldman Sachs Corruption Enforcement


In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enforcement actions by the Federal Reserve Bank and state of New York’s Department of Financial Services.
Some of the highlights include:

  • Why was the Fed involved in the Goldman Sachs FCPA resolution?
  • The Fed Order seemed critical of Goldman Sachs compliance function. Do you find this criticism warranted?
  • Is the ongoing oversight of the Fed typical for this type of case?
  • Why was the state the New York DFS involved in the Goldman Sachs FCPA resolution?
  • What were the separate reporting obligations of the Goldman Sachs compliance function discussed in the DFS Order? Do such obligations exist at the federal level?
  • Were the dates, timing and amounts of these 3 bond offerings red flags?
  • Were the money laundering allegations in funding equally as troubling as the bribery and corruption? 

Resources
Federal Reserve Cease and Desist Order
State of New York, Department of Financial Services Consent Order

Categories
FCPA Compliance Report

Jordan Arnold and Surjeet Mahant on the DFS Cyber Enforcement Action on First American Title

In this episode, I take a deep dive into the first cyber-security enforcement action brought by the state of New York, Department of Financial Services. It was against First American Title. In this exploration I am joined by Jordan Arnold, the Chief Innovation Officer at K2 Intelligence FIN. He is the founder and Global Chair of K2 Intelligence’s Private Client Services practice, which provides privacy and security services to ultra and high net worth families and clients in the entertainment, music, and sports industries and Surjeet Mahant, Managing Director in K2 Intelligence FIN’s Financial Crimes Risk and Compliance practice, where he leads cyber risk services. With over 20 years of experience in cybersecurity and privacy risk solutions for large institutions, Surjeet assists clients in developing the tools and strategies needed to protect the confidentiality of their data, the availability of their systems, and the integrity of their operations.
Some of the highlights include:

  • Overview of the enforcement action;
  • What are the broader consequences for the industry; significance of regulation/action; need for proactive actions;
  • What is the DFS and why is it regulating an insurance company around cyber?
  • Why has cyber become a part of the broader compliance conversation?
  • What specific steps can entities take to mitigate a violation or breach of data?
  • What can entities expect in the future from regulators in the cyber space?

For more information on K2 Intelligence FIN, click here.

Categories
Compliance Into the Weeds

DFS First Cyber Case-First American Title


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the first Cybersecurity breach case brought by the state of New York’s Department of Financial Services. Some of the highlights include:

  • What is the DFS?
  • What is Reg 500, Cyber Rules?
  • What were the First American comedy of errors?
  • CISO disavowed ownership of the issue, stating, among other reasons, that such controls were not the responsibility of respondent’s information security department.
  • No training for new employee charged with remediation.
  • First American said it did nothing wrong.

 Resources
See Matt’s blog post, Parsing DFS’ First Cybersecurity Case on Radical Compliance.

Categories
Daily Compliance News

Daily Compliance News: July 9, 2019, the who you gonna call edition

In today’s edition of Daily Compliance News:

  • ICO proposes a $230MM fine to BA for data breach. (CorderyCompliance)
  • Carnival Corp to hire first CCO. (WSJ)
  • Who answers 911 calls? (Hint: Not the Ghostbusters) (NYT)
  • New DFS chief wants to protect consumers. (WSJ)