Investment advisers may soon have a new cybersecurity reporting requirement from a federal regulator. Anti-money laundering (“AML”) requirements have recently been interpreted to include cybersecurity suspicious activity reporting (“SAR”) requirements, so if AML obligations – which are on the horizon – are extended to investment advisers, then these newly articulated cybersecurity reporting obligations will follow.
Click here to read this article in which SRZ lawyers discuss the Cyber-SAR Guidance set forth by FinCEN and considerations that investment advisers may want to take into account based on the new guidance.