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Tagged Posts: PII’

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

SEC Enforcement Update: Morgan Stanley Agrees To Pay $1 million Penalty for Failure to Safeguard Customer Information

November 1, 2016

As many of you know, there have been a series of big data breaches recently—the BlueCross BlueShield data breach involving more than 1 million members’ subscriber information, the Anthem data breach that exposed more than 80 million patient and employee records, and the Army National Guard data breach caused by an improper handling of data transfer to a non-accredited data center by a contract employee, among others.  With all these high-profile breaches, you’d think companies, especially big corporations, would have had a chance to review their system and close any loopholes. … Read the rest

All postings are intended to be planning tools to familiarize readers with some of the high-level issues discussed therein. No posting is intended to be a comprehensive discussion and additional details should be discussed with your transaction planners including attorneys, accountants, consultants, bankers and other business planners who can provide advice for your circumstances. This article should not be treated as legal advice to any person or entity.