FINRA Urges Firms to Heed CISA/FBI “Shields Up” Warning on Russia

The regular “Weekly Update” email from the Financial Industry Regulatory Authority (“FINRA”) had an eye-catching warning February 16, urging broker-dealer member firms to heed the “Shields Up” cyber threat warning from the Cybersecurity and Infrastructure Security Agency (“CISA”) and the FBI.

That warning urged heightened cybersecurity vigilance “related to Russia’s potential destabilizing activities against Ukraine.” The CISA alert said, “While there are not currently any specific credible threats to the U.S. homeland, we are mindful of the potential for the Russian government to consider escalating its destabilizing actions in ways that may impact others outside of Ukraine.”

CISA urged concrete steps organizations should take to:

  • Reduce the likelihood of a damaging cybersecurity intrusion;
  • Take steps to quickly detect any possible intrusion;
  • Ensure firms are prepared to respond to an intrusion; and,
  • Maximize organizational resilience.

The Shields Up notice can be found here.

CISA’s Alert (AA22-011A), “Understanding and Mitigating Russian State-Sponsored Cyber Threats to U.S. Critical Infrastructure” (Jan. 25, 2022) may be found here.

Thomas K. Potter, III (tpotter@burr.com) is a partner in the Securities Litigation Practice Group at Burr & Forman LLP. Tom is licensed in Tennessee, Texas, and Louisiana. He has over 35 years of experience representing financial institutions in litigation, regulatory, and compliance matters.

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