Cyber Enforcement Trends: What They Mean for CISOs & Other Executives in the New Line of Fire

It had been four months since our last conversation about the regulatory and enforcement focus on information security and technology executives.

The SEC had upped the ante in its enforcement action against SolarWinds and its Chief Information Security Officer Tim Brown, and there were more investigations afoot related to other major security incidents. They were not alone. Not only had the FTC and other regulators focused on individuals, but the DOJ had also recently reaffirmed its view that the best way to effect corporate change was to focus on individuals. The landscape was continuing to evolve – and there was more happening behind the scenes.

Three experienced legal advisors and a leading CISO on the front lines of these trends discussed ideas for how they could prepare.

• Aravind Swaminathan, Partner, Global Co-Chair, Cybersecurity and Data Privacy, Orrick, Herrington & Sutcliffe
• Jerry Archer, Senior Advisor, McKinsey & Company (Former CISO for Sallie Mae)
• Luke Dembosky, Partner, Co-Chair, Global Data Strategy and Security practice
• Ken Herzinger, Global Co-Chair, Investigations and White-Collar Defense, Paul Hastings