SEC 2025 Examination Priorities Indicate Sustained Focus on Cybersecurity & Data Protection

Our Privacy, Cyber & Data Strategy and Investment Management, Trading & Markets Teams review the Securities and Exchange Commission’s potentially transformative proposed rules that would require registered investment advisers, investment companies, and business development companies to strengthen their cybersecurity programs.

Our Investment Funds and White Collar, Government & Internal Investigations Groups discuss what investment fund advisers and broker-dealers should know about the Securities and Exchange Commission’s Division of Examinations’ priorities for fiscal year 2025.

Alston & Bird has expanded its Privacy, Cyber & Data Strategy Team with the addition of partner Kelly Hagedorn in the firm’s London office. With extensive cyber incident response experience, Kelly advises clients on data protection, regulatory enforcement, and privacy litigation.

Two and a half years after the first major settlement with some of the world’s largest financial institutions, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) persist in their campaign against using off-channel communications. Our Investment Funds, Privacy, Cyber & Data Strategy, and White Collar, Government & Internal Investigations Groups unpack the latest enforcement actions, including how the agencies are looking for substantial settlements from smaller registrants.

The Securities and Exchange Commission’s cybersecurity-related case against SolarWinds and its CISO was largely dismissed, but a securities fraud claim against the CISO lives on. Our Securities Litigation, Privacy, Cyber & Data Strategy, and Securities teams break down the court’s reasoning.