National Futures Association (NFA)

Cybersecurity and data privacy presented some of the most complex legal questions and business risks that multinational companies faced in 2018. Businesses should expect continued growth in cyber and data privacy challenges in 2019.

Cyber attacks became even more sophisticated and severe in 2018, with incidents ranging from exfiltration and extortion schemes, to attacks on

On January 7, 2019, the US self-regulatory organization the National Futures Association (“NFA”) announced that it had adopted amendments to its information security requirements that include a cybersecurity incident notification obligation.1 As discussed below, the NFA’s amendments represent the continued maturation of information security in the US financial services sector and are incremental, rather