2011

The Society for Worldwide Interbank Financial Telecommunication, or SWIFT, provides an organizational platform for facilitating international payments.  U.S. and foreign financial institutions use SWIFT messages to initiate, process, receive, and settle payment orders.  The amount of information exchanged via SWIFT is immense.  More than 9,000 financial institutions in 209 countries rely on SWIFT to process

The EU Art 29. Working Party finished its 80th plenary meeting in Brussels last week.  This week, the Party released a series of new policy opinions produced during the plenary.  The highlights included:

  • A declaration that, in WP 29’s opinion, New Zealand’s data protection regime is now “adequate” for the purposes of international data transfer.  This opinion will now be

On April 7, 2011, the Securities and Exchange Commission announced a total of $55,000 in fines against three former executives of a securities broker-dealer for violations of the privacy and safeguard rules in Regulation S-P.  The fines mark the first time the SEC has imposed administrative fines for violations of these rules.  Copies of the

I’ve recently had the opportunity to participate in or moderate several panels on cloud computing, addressing issues such as governance, security, privacy, and legal liability.  
One issue that frequently comes up is whether cloud computing is really new or different.  That depends on how you look at it.  As a legal matter, the model itself