Bridging the Weeks by Gary DeWaal: October 1 - 12 and October 15, 2018 (Self-Reporting Pays; Costly Cyber-Attack; No Systemic Threat by Crypto-Assets)

Published Date: October 15, 2018

An international bank settled an enforcement action brought by the Commodity Futures Trading Commission for spoofing. However, in the process, the CFTC went out of its way to laud the bank for self-reporting the incident, as well as its cooperation in the CFTC’s investigation and voluntary efforts to enhance its internal processes to detect spoofing and train staff going forward. Separately, a UK-based financial institution was assessed a fine of the equivalent of approximately US $21.5 million by the Financial Conduct Authority for a cyber breach that detrimentally impacted some customers. Although the FCA acknowledged that the bank’s cybercrime framework was “appropriate,” it said that employees did not follow it. As a result, the following matters are covered in this week’s edition of Bridging the Weeks:

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Gary DeWaal

Gary DeWaal is currently Special Counsel with Katten Muchin Rosenman LLP in its New York office focusing on financial services regulatory matters. He provides advisory services and assists with investigations and litigation.

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Gary DeWaal
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