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Abstract: 

Regulators and prosecutors are flexing their enforcement muscles in new and sometimes novel ways. New York officials have brought significant actions against non-US banks for violating US sanction regulations. The SEC and the CFTC have used expansive views of supervisor liability to extend failure-to-supervise charges beyond direct line supervisors. Federal officials are using FIRREA to bring civil charges against financial institutions instead of on their behalf. And the SEC is investigating potential FCPA violations by financial institutions in connection with sovereign wealth funds and hiring practices. The authors discuss these developments.

Keywords: Cyber-Specific Insurance Policies; Securing Coverage after a Cyber-Event

Affiliations:  1: Haynes and Boone, LLP.