Vulnerability assessments and penetration testing enter the realm of information security (IS) professionals. It is important to note that information security is a sub-specialty of information technology and most “IT guys” are not trained in information security. Therefore, it’s important … Read More
“I don’t measure a man’s success by how high he climbs but how high he bounces back when he hits the bottom.” ~General George Patton As another year is quickly coming to a close, so often organizations reflect on metrics … Read More
All compliance officers are de facto project managers. Whether you are conducting an internal audit, authoring and implementing policies and procedures, rolling out new compliance technology, or training employees on compliance requirements – all these projects go towards helping your … Read More
On November 16, 2015, the Securities and Exchange Commission (“SEC”) issued administrative and cease and desist proceedings against Virtus Investment Advisers, Inc. (“Virtus”) for marketing a “materially inflated, and hypothetical and back-tested, performance track record” of one of its sub-advisers, … Read More
Unauthorized Access Cybersecurity is essentially a regime to prevent unauthorized access. Authorized users are authenticated most commonly via a username and password. However, requiring just a password with a username for access is considered a weak protection control. Weak because … Read More
Recently the Securities and Exchange Commission (“SEC”) charged a St. Louis Investment adviser that had experienced a breach of client non-public information with failing to create and implement cybersecurity policies and procedures. According to the SEC’s press release, for over … Read More
On August 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury (“Treasury”), proposed a rule that would “prescribe minimum standards for anti-money laundering programs (“AML”) to be established by investment advisers.” This rule would … Read More
On August 19, 2015, The Securities and Exchange Commission “SEC” announced that Citigroup Global Markets (“Citigroup”) has agreed to settle charges that it failed to enforce policies and procedures to prevent and detect securities transactions that could involve the misuse … Read More
On July 30, 2015 Curian Capital (“Curian”), an SEC registered asset management firm, surprised the industry by posting a notice on their website stating they will no longer accept any new business and will only continue to manage existing … Read More
