Alternative asset managers must contend with numerous cybersecurity issues, including emerging threats; potential breaches in a pre-acquisition and post-acquisition context; special considerations for breaches of investor or consumer data; the handling of cybersecurity issues in the investment fund context; and the proper response to breaches. These topics were addressed in a recent panel hosted by Brian T. Davis and Dimitri G. Mastrocola, partners at international recruiting firm Major, Lindsey & Africa (MLA), and featuring Debevoise & Plimpton partners Luke Dembosky and Jim Pastore, both of whom are former federal prosecutors. This article highlights the key points from the presentation. For more on cybersecurity, see “Growing SEC Enforcement of Hedge Fund Managers Requires Greater Focus on Cybersecurity and Financial Disclosure” (Jul. 7, 2016); “SEC Chief of Staff Outlines Asset Management Initiatives on Cybersecurity and Transition Planning and Emphasizes Robust Enforcement Environment” (Jul. 7, 2016); and “SEC Guidance Update Suggests a Three-Step Framework for Investment Manager Cybersecurity Programs” (May 7, 2015). For coverage of a prior program hosted by MLA, see our two-part series on SEC examinations: “What Hedge Fund Managers Need to Know” (Jun. 16, 2016); and “Fees, Conflicts, Investment Allocations and Other Hot Topics” (Jun. 30, 2016).
Oct. 6, 2016
Former Prosecutors Address Trends in Cybersecurity for Alternative Asset Managers, Diligence When Acquiring a Company and Breach Response Considerations
- Vincent PitaroHedge Fund Law Report
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