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Two Lessons from Goldman Sachs’s $36.3 Million Penalty for Unauthorized Use and Disclosure of Confidential Supervisory Information

January 3, 2017

Previously, we discussed the Securities and Exchange Commission’s (“SEC”) order against Morgan Stanley Smith Barney LLC (“Morgan Stanley”) in connection with the company’s failure to safeguard customer information (see the SEC order here).  As we reported earlier, there have been a number of high profile data breaches lately, resulting in big administrative penalties and consent orders against violators.  The Federal Reserve Board’s (“FRB”) order on August 2, 2016 (the “order”), directing The Goldman Sachs Group, Inc. (“Goldman Sachs”) to pay a $36.3 million civil monetary penalty—significantly bigger the $1 million penalty that Morgan Stanley was ordered to pay in June—for its unauthorized use and disclosure of confidential supervisory information, is the latest such event.… Read the rest

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