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Looking to the FFIEC Revised Information Security Booklet for Best Practices in Data Security for Financial Institutions
The Federal Financial Institutions Examination Council (FFIEC) recently revised its Information Security Booklet. The changes bring the financial services industry closer to the goal of having a clearly defined set of cybersecurity and data protection protocols to ensure regulatory compliance. The booklet is one of 11 which together comprise the FFIEC IT Handbook. Special focus should be paid to the updated Appendix A which was published as guidance for field examiners of the financial services regulators to assess the level of security risks to an institution's information systems and the adequacy of an information security program's integration into an institution's overall risk management.
The Appendix lists 11 objectives for examiners to utilize, however eight of these objectives can be used as internal guidance to assess a program and devise a set of best practices to structure policies and procedures to form a strong, compliant approach to data security ahead of any examination.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
A Lawyer's System for Active Reading
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.