Securities,
Government,
Corporate,
Administrative/Regulatory
Jun. 5, 2019
Cybersecurity and the future of SEC enforcement
What responsibilities do U.S. public companies have to prevent theft of company funds through cybercrime? Recent Securities and Exchange Commission guidance suggests that the SEC may be considering a new type of enforcement action to address this question.





Michael M. Farhang
Partner
Gibson Dunn & Crutcher LLP
Email: mfarhang@gibsondunn.com
Michael is a former federal prosecutor and a partner in the firm's Los Angeles office. He is a Chambers-ranked attorney and practices in the White Collar Defense and Investigations and Securities Litigation Practice Groups.
What responsibilities do U.S. public companies have to prevent theft of company funds through cybercrime? Recent Securities and Exchange Commission guidance suggests that the SEC may be considering a new type of enforcement action to address this question. In October 2018, the SEC issued an investigation report examining nine companies defrauded by cyber-related intrusion and fraud schemes. The report suggests that the agency may adapt an old enforcement tool -- the i...
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