Partner at Debevoise & Plimpton, Former Cybercrime Federal Prosecutor, Former Chief Counsel for Cyber, Privacy and Data
CISO’s feel like they are under a spotlight after the recent criminal conviction of a CISO and the charges by the SEC. The good news is that these are two examples out of hundreds of major breaches. That is, CISO liability is still extremely rare. But even these 2 instances are enough to generate very reasonable fear in the CISO community. We propose a framework for the SEC to consider before they act on this again.
Executive Director, NYU Law Program on Corporate Compliance and Enforcement | Former SDNY Federal Prosecutor | Law Professor
Andrew Ceresney, Charu Chandrasekhar, Luke Dembosky, Erez Liebermann, Julie Riewe, Anna Moody, Andreas Glimenakis, and Melissa Muse outline how #CISOs can avoid #liability from the U.S. Securities and Exchange Commission for #cybersecurity lapses leading to a #databreach in NYU Program on Corporate Compliance and Enforcement's blog: https://lnkd.in/euhhnEGJ Jennifer Arlen, Carolyn R Pautz, PhD, Julius Sim
Nothing great has ever been accomplished by generating fear among people, regardless of whether it is reasonable or not. Honest mistakes/oversights can happen in any role at any level, and it is the actions taken after such events that really speak to the reasonableness of any subsequent investigation by external entities. Sajed Naseem I believe you have nothing to worry about even though this article is very unsettling.
Thanks Erez Liebermann for your leadership. I advise the #cisos community to shield themselves from liability by aligning their cyber risk reporting to the NACD (National Association of Corporate Directors) boardroom standard and mapping to materiality thresholds . Learn more at https://www.nacdonline.org/nacd-board-advisory-services/cyber-risk-reporting-services/
privacy attorney, digital forensics examiner, adjunct professor, cybersecurity advisor
9moConviction? I thought he was only charged, just a few weeks ago. Did he plead out?