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Jan. 17, 2024

2024 SEC Examination Priorities: New Approaches to Old Areas of Concern

  • Rorie Norton and Hena Lees
    Cybersecurity Law Report
The SEC Division of Examinations indicated, in its published 2024 examination priorities (Annual Priorities), that it will continue to use a risk-based approach and focus examinations on certain practices, products and services that it believes present potentially heightened risks to investors or the integrity of U.S. capital markets. For 2024, this focus will include, among other things, information security and operational resiliency, and crypto assets and emerging financial technology. To help organizations regulated by the SEC prepare for potential scrutiny in the coming year, this article summarizes the key takeaways from the Annual Priorities, with insights from Davis Polk and Simpson Thacher along with some of the Division’s leadership’s high-level systemic observations of ongoing efforts. See “Navigating SEC Cybersecurity Enforcement in a Post-SolarWinds World” (Nov. 15, 2023).

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