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Historic Charges: First Enforcement Action Filed by New York Department of Financial Services Under Cybersecurity Regulation

Data Matters

On July 21, 2020, the New York State Department of Financial Services (NYDFS or the Department) issued a statement of charges and notice of hearing (the Statement) against First American Title Insurance Company (First American) for violations of the Department’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R.

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$8 million penalty to NYDFS – and another case of over-retention

Data Protection Report

On January 3, 2024, the New York Department of Financial Services announced a consent order with GGT, where GGT agreed to pay NYDFS $8 million and to surrender its BitLicense (for cryptocurrency trading), due to alleged violations of NYDFS’ cybersecurity and its virtual currency regulations.

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NYDFS settles cybersecurity regulation matter for $1.8 million

Data Protection Report

On May 13, 2021, the New York Department of Financial Services (NYDFS) announced a $1.8 million settlement with two related insurance companies, relating to violations of two different requirements of the NYDFS cybersecurity regulation during the period 2018 to 2019. Affiliate #1 notified NYDFS on November 25, 2019.

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SEC Announces Settled Charges Against First American for Cybersecurity Disclosure Controls Failures – Lessons Learned

Data Matters

The SEC is considering enhancing its disclosure rules concerning cybersecurity risk governance and has indicated a target release date of October 2021. enable companies to identify cybersecurity risks and incidents. evaluate the significance associated with such risks and incidents.

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Regulatory Update: NAIC Summer 2019 National Meeting

Data Matters

The National Association of Insurance Commissioners (NAIC) held its Summer 2019 National Meeting (Summer Meeting) in New York City from August 3 to 6, 2019. The amended regulation took effect on August 1, 2019, for annuity products and will become effective on February 1, 2020, for life insurance products.

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Cryptoassets and Smart Contracts – UK Offers Legal Clarity

Data Matters

On November 18, 2019, the UK Jurisdiction Taskforce, which is part of The English Law Society’s LawTech Delivery Panel , published its Legal Statement on the status of cryptoassets and smart contracts (the Legal Statement). 5 The consequences of this are important, however.

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Cryptoassets and Smart Contracts – UK Offers Legal Clarity

Data Matters

On November 18, 2019, the UK Jurisdiction Taskforce, which is part of The English Law Society’s LawTech Delivery Panel , published its Legal Statement on the status of cryptoassets and smart contracts (the Legal Statement). 5 The consequences of this are important, however.