This article appeared in Cybersecurity Law & Strategy, an ALM publication for privacy and security professionals, Chief Information Security Officers, Chief Information Officers, Chief Technology Officers, Corporate Counsel, Internet and Tech Practitioners, In-House Counsel. Visit the website to learn more.

Cybercrime poses an ever-increasing threat to consumers of financial products and services. In 2016, the then- U.S. Securities and Exchange Commission (SEC) Chair said that cybercrime ranks as “one of the greatest risks facing the financial services industry.” Federal law thus requires financial services firms to implement procedures designed to protect their customers’ data.