Please join us for a program focused on the latest 2021 FinTech and blockchain developments. Sidley lawyers in the banking, white collar, and FinTech groups will discuss the key regulatory and enforcement issues related to enhanced focus by the DOJ, SEC, CFTC, FinCEN, CFPB, OCC, and Federal Reserve on FinTech, blockchain, and cryptocurrencies from both the criminal and civil enforcement perspectives.

Events; Financial Privacy; FinTech; Policy

Regulatory Update: NAIC Summer 2021 National Meeting

Sep 20 2021

Stephanie H. Dobecki, Ellen M. Dunn, Andrew Holland, Michael L. Rosenfield, Chris Burusco, Sara N. Africano and Jacob A. Grossman

The National Association of Insurance Commissioners (NAIC) held its Summer 2021 National Meeting (Summer Meeting) August 14-17, 2021. As a result of the continuing COVID-19 pandemic, the NAIC met in a hybrid format with attendees participating both in person and virtually. This post summarizes the highlights from this meeting in addition to interim meetings that were held during July in lieu of taking place during the Summer Meeting. Highlights include, among others, adoption of revised risk-based capital bond factors for life insurers, amendments to SSAP No. 71, and an amendment to the purposes and procedures manual to add instructions for review of funds.

Cybersecurity; Insurance; Policy

New European Union Dual-Use Regulation Enters Into Force

Sep 09 2021

Sven De Knop, Justine Fassion and Alessandra Moroni

As from September 9, 2021, Regulation (EU) 2021/821 (EU Dual-Use Regulation Recast) replaces the existing Council Regulation (EC) 428/2009 setting up the European Union (EU) regime for the control of exports, transfer, brokering, and transit of “dual-use” items (EU Dual-Use Regulation). Dual-use items are sensitive goods, services, software, and technology that can be used for both civil and military purposes.

EU; General; International

SEC Continues Focus on Cybersecurity Disclosure Failures, Announces Settled Charges Against Pearson plc

Aug 30 2021

Alan Charles Raul, Colleen Theresa Brown, Stephen L. Cohen, Sara B. Brody, Sujit Raman, Geeta Malhotra, Michael R. Roberts and Laura Sorice

Through its announcement of settled charges against Pearson plc (Pearson) on August 16, 2021, the U.S. Securities and Exchange Commission signaled its continued, high level scrutiny of companies’ public statements related to data security incidents.¹ Without admitting or denying the SEC’s findings, Pearson agreed to a cease and desist order (Order) and to pay a $1 million penalty.² The SEC’s Pearson Order follows its June 2021 announcement that it had settled charges against First American Title Insurance Company (First American) for cybersecurity disclosure control failures.³ Together, the Pearson and First American actions underscore the SEC’s increasingly vigorous enforcement efforts on disclosure control violations related to cybersecurity issues, in particular vulnerabilities that expose sensitive customer information and data breaches.

Cybersecurity; Enforcement; SEC

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Fintech and Blockchain 2021

Regulatory Update: NAIC Summer 2021 National Meeting

New European Union Dual-Use Regulation Enters Into Force

SEC Continues Focus on Cybersecurity Disclosure Failures, Announces Settled Charges Against Pearson plc

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