Navigating FCA and SEC Cybersecurity Expectations (Part One of Two)

Given the increased scrutiny of cybersecurity by governments around the globe, regulated entities operating in more than one jurisdiction must be aware of the relevant regulatory cybersecurity expectations.  This two-part series looks at the operations of the U.K. Financial Conduct Authority (FCA) and the SEC, both of which have increased their focus on cybersecurity, but with differing approaches.  Part One discusses the FCA and SEC as regulators of financial services in their respective jurisdictions and outlines the guidance issued, and the methods adopted, by the two regulators.  Part Two will explore how the financial sector is navigating the current regulatory environments, including existing guidance, in the U.S. and abroad and how the industry can simultaneously satisfy the requirements of each regulator.  See also “Meeting Expectations for SEC Disclosures of Cybersecurity Risks and Incidents (Part One)” (Aug. 12, 2015) and Part Two (Aug. 26, 2015).

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