The CFTC’s enforcement action against AMP Global Clearing LLC highlights the need for funds, fund sponsors, and advisers to adequately supervise their service providers’ cybersecurity measures, according to a team of investment management and cybersecurity attorneys at Ropes & Gray LLP. In their view, the AMP action underscores the ease with which a regulated entity can find itself in the crosshairs of an enforcement action. They believe that comprehensive, documented technical and physical safeguards for customer records and information alone are not sufficient, and advise funds, fund sponsors, and advisers to engage in a more rigorous level of oversight of the cybersecurity activities of their vendors.
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