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Caesars entertainment filed an 8-K following disclosure of a cyber incident, that came to light publicly during the MGM resorts hack. Confirming that it was compromised following a social engineering attack on an IT support vendor. Resulting in a data breach of its loyalty program database.
From December 2023 a registrant is required to ‘describe the material aspects of the nature, scope, and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.’
‘disclose specific or technical information about its planned response to the incident or its cybersecurity systems, related networks and devices, or potential system vulnerabilities in such detail as would impede the registrant’s response or remediation of the incident.’
One wonders if a reasonable investor would conclude that the breach of the customer loyalty data base is material? If a ransomware was paid, would a reasonable investor expect it to be disclosed? Would the potential for legal and regulatory sanctions be disclosed (likely material impact for a reasonable investor)?
Ted Dziekanowski Rachel V. Rose, JD, MBA Bob Dix
#cybersecurity #cyberriskmanagement #cyberregulation
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