In April, we wrote that the Financial Stability Board (FSB) was seeking comment on 46 recommended cyber incident response and recovery (CIRR) practices for financial institutions. On October 19, the FSB published its final “toolkit” consisting of 49 recommendations (Report). Although the FSB tends to focus more on systemically important financial institutions, we think that all capital markets participants will find it worthwhile to read the final Report. The FSB expects that firms of various sizes and with different business models will choose to adopt, and adapt, some or all of the recommendations as appropriate, taking into account their size, complexity and risks to the financial system.

AUM Law can help you assess and enhance your cyber security policies and procedures and conduct training in this area for your employees. Please contact us to find out more about our services in this area.

October 30, 2020