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

To address the divergent expectations and requirements of relevant regulators, hedge fund managers operating in multiple jurisdictions must develop a coordinated approach to cybersecurity when designing cyber-compliance programs. This two-part series examines the operations of the U.K. Financial Conduct Authority (FCA) and the SEC, both of which have increased their focus on cybersecurity, albeit with differing approaches. Part One discussed the FCA and SEC as regulators of financial services in their respective jurisdictions and outlined the guidance issued, and the methods adopted, by the two regulators. This article explores how hedge fund managers can navigate the current regulatory environments, including existing guidance, in the U.S. and the U.K., and simultaneously satisfy the requirements of each regulator. See also “RCA Panel Outlines Keys for Hedge Fund Managers to Implement a Comprehensive Cybersecurity Program” (Jun. 18, 2015).

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