Please join us on Wednesday, February 24th, for a roundtable focusing on the latest developments in two of today’s “hottest” regulatory and compliance topics – anti-money laundering and cybersecurity/data privacy.
Our panelists will cover, among other things:
- Update on the current anti-money laundering enforcement environment
- Practical implications of proposed FinCEN AML rule for investment advisers
- Potential impact of proposed FinCEN CDD requirements
- Incremental effect of proposed New York Department of Financial Services rule on transaction monitoring, filtering program and other requirements
- Key items to address before a cybersecurity incident
- Impact of the Cybersecurity Act of 2015
- Evolving governmental and regulatory approaches to cybersecurity
- Important lessons learned from cybersecurity breach experience
8:00 a.m. – 8:30 a.m.
Registration and Breakfast
8:30 a.m. – 9:45 a.m.
Anti-Money Laundering: Recent Regulatory Developments and Evolving Compliance Challenges
9:45 a.m. – 10:00 a.m.
10:00 a.m. – 11:15 a.m.
Cybersecurity and Data Privacy: Addressing Increasing Risks and Heightened Regulatory Requirements
This program is designed to bring compliance officers and others interested in compliance issues in the New York metropolitan area together to share information and discuss hot topics. The information provided at this program does not constitute legal advice. This program will not be recorded and is not for attribution.
Sidley Austin LLP is an Approved Accredited Provider of CA, IL and NY CLE credit. CLE credit is pending for this program.
The Cybersecurity Act of 2015, which included the long anticipated Cybersecurity Information Sharing Act or CISA, was passed on December 18, 2015 to facilitate and encourage confidential two-way private sector sharing of cyberthreat information with the federal government. It also provided key liability shields for cyberthreat information sharing and network monitoring pursuant to the Act. Under the Cybersecurity Act, the Department of Homeland Security (DHS) was designated to coordinate the sharing and was tasked with developing guidelines to facilitate implementation within 90 days.
Sidley speaker: Edward R. McNicholas
On February 3, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced that an HHS administrative law judge (ALJ) ordered Lincare, Inc., a home health provider of respiratory care, infusion therapy and medical equipment, to pay $239,800 in civil monetary penalties (CMPs) for violating the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule. The violations were disclosing patient information to an unauthorized person, failing to take reasonable safeguards to protect patient information from unauthorized disclosure and failing to implement adequate policies and procedures to protect patient information removed from its offices. This marks only the second time that OCR has imposed CMPs for HIPAA violations.
The TPI Aspen Forum brings together leaders from business, government, and academia to discuss key public policy issues affecting information and communications technology.
Sidley Speaker: Alan Charles Raul
President Obama today unveiled a “Cybersecurity National Action Plan.” The administration’s proposed budget includes $19 billion for cybersecurity spending, $3 billion of which will be devoted to updating agency systems. The plan includes the creation of a Federal Chief Information Security Officer to guide the implementation of increased security across the federal government and reside within the Office of Management and Budget. President Obama also issued two executive orders. The first establishes the Commission on Enhancing National Cybersecurity within the Department of Commerce to be composed of technology, national security, and business leaders. The Commission is charged with developing by December 1, 2016 “detailed recommendations to strengthen cybersecurity in both the public and private sectors.” The second requires the establishment of a Senior Agency Official for Privacy at each agency and creates the Federal Privacy Council as “the principal interagency forum to improve the Government privacy practices of agencies and entities acting on their behalf.” The OMB Director will be chair of the Federal Privacy Council, which will have the focus of coordinating internal agency policies.
On February 2, 2016, the European Commission announced that an agreement had been reached regarding a new framework for the transfer of data to the U.S.: the EU-U.S. Privacy Shield. According to Vice-President of the European Commission, Andrus Ansip, and Commissioner for Justice, Consumers and Gender Equality, Věra Jourová, who made the announcement, the new arrangement reflects the requirements set out by the Court of Justice of the European Union in Maximillian Schrems v. Data Protection Commissioner (C-362-14), and is due to come into force within three months. On February 5, Sidley and DataGuidance presented a live webinar to investigate the new agreement featuring Sidley partners William Long, who advises on European privacy law, Maarten Meulenbelt, who advises on EU regulatory affairs, and Alan Charles Raul, co-leader and founder of Sidley’s Privacy, Data Security and Information Law practice.
Sidley Speaker: Edward McNicholas
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