A likely outcome of the SEC consolidating its crypto and cyber enforcement teams and increasing its size may well be a robust pipeline of work. One wonders Ted Dziekanowski if the combination of a robust well tested whistleblower program alongside…
U.S army is moving forward with the Risk management Framework 2.0, under FISMA. This is important for those companies that wish to deal with the DoD, as risk management become an integral part of defence procurement and supply and mission.…
A very interesting article on cybersecurity, the False Claims Act and use of whistleblower programs. No public or private organisation, including those outside the U.S. that provide products and services to U.S. Federal agencies, should discount the whistleblower regime. Whistleblower…
Thank you Ted Dziekanowski, the DoJ settlement is an example of the challenges ahead for cybersecurity. The DoJ civil cyber fraud initiative and the enclosed settlement is an example of the regulatory enforcement that is being tested in the US.…
A great article that is well worth reading, bringing together cybersecurity, regulation and litigation. The regulatory landscape for cybersecurity is developing at a rapid rate. The SEC recently released a cybersecurity proposal, the DoD CMMC program requires DFARS compliance, there…
We presented a proposal to the DoD, Cyberspace Solarium Commission, NDIA and AICPA in 2021 to manage DFARS and CMMC compliance. We called it the Augusta Plan 1.0, or Augusta Plan 2.0 to enable CMMC, FISMA and OMB A130 compliance.…
I wonder where the FCA will go with cybersecurity risk management compliance Bryan Foss if the SEC proposal on cybersecurity risk management, strategy, governance and incident disclosure is formalised. It requires boards to disclose corporate cybersecurity risks, their cybersecurity experience,…
I am looking forward to today’s conversation on the SECs cybersecurity proposal with the The Institute of Internal Auditors Inc. Ted Dziekanowski, the more you immerse yourself into the SECs proposal, the more you understand that the SECs requirements are…
Are we at a pivot point with cyberspace and the application of international law? Traditional rules of engagement and domains of operation do not apply in cyberspace and cyber related attacks are difficult to trace and legally enforce. This is…
Gary Gensler the chair of the SEC discusses the recent proposal for climate reporting and a brief history on long tradition the SEC has in disclosure and its relevance to climate related disclosures. Over the generations, the SEC has stepped…
