Cyber-security has become – or perhaps should be – a key area of concern for every enterprise. The risks are substantial for the firm, its shareholders, executives and customers as recent cases illustrate. Every enterprise large or small is a potential victim. The losses can and often are substantial not just in dollars but also in trust, customers and more. The Commission has issued guidance. The agency has also brought enforcement actions.
Now, however, the Commission has issued a report based on nine investigations of firms involved in a variety of industries, cautioning about cyber risks in the context of the firm’s obligations to maintain proper internal controls. Report of Investigation Pursuant to Section 21(a) of the Exchange Act Regarding Certain Cyber-Related Frauds Perpetrated Against Public Companies, October 16, 2018.