small-logo
ProfessionalsCapabilitiesInsights & NewsCareersLocations
About UsAlumniOpportunity & InclusionPro BonoCorporate Social Responsibility
Stay Connected:
facebookinstagramlinkedintwitteryoutube
  1. Privacy & Data Security

Blog

CFTC Assesses its Oversight of Registrant’s Cybersecurity Policies

  • PDFPDF
    • Email
    • LinkedIn
    • Facebook
    • Twitter
    Share this page
  • PDFPDF
    • Email
    • LinkedIn
    • Facebook
    • Twitter
    Share this page

Blog

CFTC Assesses its Oversight of Registrant’s Cybersecurity Policies

  • PDFPDF
    • Email
    • LinkedIn
    • Facebook
    • Twitter
    Share this page

1 Min Read

Related Locations

Chicago
New York

Related Topics

Financial Privacy

Related Capabilities

Privacy & Data Security
Financial Services

Related Regions

North America

December 27, 2016

A performance audit of the U.S. Commodity Futures Trading Commission’s (CFTC) policies and procedures for reviewing CFTC registrant’s cybersecurity polies was recently posted online. The goal of the audit was to reduce the cybersecurity risks of the financial organizations that are overseen by the CFTC. The audit was conducted by the CFTC’s Office of the Inspector General, which contracted with a third party to perform the actual review. The CFTC’s response to the report highlights recently approved rules regarding cybersecurity testing by registrants that require external and internal penetration and vulnerability testing at a frequency determined by appropriate risk analysis. The report also recommends use of a risk-based approach to test registrants’ cybersecurity preparedness, which testing is currently conducted by the National Future Association rather than the CFTC directly. 

TIP: The audit and the new rules referenced in the CFTC’s responses thereto highlight the growing importance of cybersecurity. Registrants that fall within CFTC oversight should keep in mind the significance that both the CFTC and the NFA place on preventing cybersecurity incidents by registrants, the additional testing requirements and the increased focus on registrant’s cybersecurity preparedness.

This entry has been created for information and planning purposes. It is not intended to be, nor should it be substituted for, legal advice, which turns on specific facts.

Logo
facebookinstagramlinkedintwitteryoutube

Copyright © 2025. Winston & Strawn LLP

AlumniCorporate Transparency Act Task ForceDEI Compliance Task ForceEqual Rights AmendmentLaw GlossaryThe Oval UpdateWinston MinutePrivacy PolicyCookie PolicyFraud & Scam AlertsNoticesSubscribeAttorney Advertising