Client Alert: Recent SEC Settlement Underscores Focus on Financial Institutions Facing Cyber Intrusions

The SEC last week announced a settlement with a Colorado-based registered broker-dealer for allegedly failing to file Suspicious Activity Reports (SARs) and filing incomplete SARs on attempted cyber intrusions into its customers’ electronic retirement accounts. The settlement is in the wake of the SEC’s 2021 examination priorities and a March 2021 SEC risk alert emphasizing that broker-dealers must file complete SARs when bad actors attempt to gain access to customers’ online accounts or electronically stored personal data. The SEC’s order also follows guidance issued from the Financial Crimes Enforcement Network (FinCEN) to banks, casinos, broker-dealers, and other entities that are required to file SARs (Reporting Entities) emphasizing that FinCEN expects Reporting Entities to file complete SARs on all cyber-intrusions.[1]

This client alert examines the SEC’s recent settlement with a broker-dealer for failing to file SARs—including for failure to file adequately detailed SARs—on cyber-intrusion events, summarizes recent guidance by the SEC and other federal regulators on SAR filings on cyber-intrusions, and discusses the key takeaways from the SEC’s recent action and agency guidance on cyber-events. 

To read the full alert, please click here

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: Recent SEC Settlement Underscores Focus on Financial Institutions Facing Cyber Intrusions

The SEC last week announced a settlement with a Colorado-based registered broker-dealer for allegedly failing to file Suspicious Activity Reports (SARs) and filing incomplete SARs on attempted cyber intrusions into its customers’ electronic retirement accounts. The settlement is in the wake of the SEC’s 2021 examination priorities and a March 2021 SEC risk alert emphasizing that broker-dealers must file complete SARs when bad actors attempt to gain access to customers’ online accounts or electronically stored personal data. The SEC’s order also follows guidance issued from the Financial Crimes Enforcement Network (FinCEN) to banks, casinos, broker-dealers, and other entities that are required to file SARs (Reporting Entities) emphasizing that FinCEN expects Reporting Entities to file complete SARs on all cyber-intrusions.[1]

This client alert examines the SEC’s recent settlement with a broker-dealer for failing to file SARs—including for failure to file adequately detailed SARs—on cyber-intrusion events, summarizes recent guidance by the SEC and other federal regulators on SAR filings on cyber-intrusions, and discusses the key takeaways from the SEC’s recent action and agency guidance on cyber-events. 

To read the full alert, please click here

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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