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CFTC Orders AMP Global Clearing LLC to Pay $100,000 for Supervision Failures Related
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CFTC Orders AMP Global Clearing LLC to Pay $100,000 for Supervision Failures Related

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CFTC Orders AMP Global Clearing LLC to Pay $100,000 for Supervision Failures Related

RELEASE: pr7693-18

February 12, 2018

CFTC Orders AMP Global Clearing LLC to Pay $100,000 for Supervision Failures Related to Cybersecurity of its Customersí Records and Information

Washington, DC*Ė The Commodity Futures Trading Commission (CFTC) today issued an Order filing and simultaneously settling charges against*AMP Global Clearing LLC*(AMP), a registered Futures Commission Merchant since 2010, for its failure between June 21, 2016 and April 17, 2017 to supervise diligently the implementation of critical provisions in AMPís information systems security program (ISSP). As a result of this failure, a significant amount of AMPís customersí records and information were left unprotected for nearly ten months. In April 2017, as a result of this failure, a third party unaffiliated with AMP (Third Party) accessed AMPís information technology network and copied approximately 97,000 files, which included customersí records and information, including personally identifiable information. The Third Party thereafter contacted federal authorities about securing the copied information, and subsequently informed AMP that the copied information had been secured and was no longer in the Third Partyís possession. After becoming aware of the vulnerability and unauthorized access, AMP cooperated with the CFTC and worked diligently to remediate the issue.

CFTCís Director of Enforcement Comments

James McDonald, the CFTCís Director of Enforcement, commented: ďEntities entrusted with sensitive information must work diligently to protect that information. Thatís not only good business, but when it comes to registrants in our markets, itís the law. As this case shows, the CFTC will work hard to ensure regulated entities live up to that responsibility, which has taken on increasing importance as cyber threats extend across our financial system.Ē

Specifically, the Order finds that AMP failed to supervise its IT Providerís implementation of ISSP provisions it was delegated with implementing under AMPís supervision, including identifying and performing risk assessments of access routes into AMPís network, performing quarterly network risk assessments to identify vulnerabilities, maintaining strict firewall rules, and detecting unauthorized activity on the network. This failure left a significant amount of AMPís customersí records and information vulnerable to cyber-exploitation for nearly ten months, until the Third Party accessed AMPís network.

The Order finds that the vulnerability in AMPís network involved an open access route in a network attached storage device (NASD). Three successive quarterly network risk assessments failed to identify this vulnerability. Indeed, the Order finds that, before the Third Party accessed the NASDís contents, the media had reported three other incidents of unauthorized access of NASDs used by organizations other than AMP, including some from the same manufacturer of AMPís NASD. Yet AMP did not detect the vulnerability until its network was accessed and customer records and information compromised.

The Order requires AMP to pay a $100,000 civil monetary penalty and cease and desist from violating the CFTC regulation governing diligent supervision. The Order further requires AMP to provide two written follow-up reports, within one-year of entry of the Order, to the CFTC verifying AMPís ongoing efforts to maintain and strengthen the security of its network and its compliance with its ISSPís requirements.

The Order recognizes AMPís substantial cooperation and remediation during the CFTCís Division of Enforcementís investigation of this matter, which included providing important information and analysis to the Division that helped the Division to efficiently and effectively undertake its investigation. The Order notes that the civil monetary penalty imposed on AMP reflects AMPís cooperation.

The CFTC thanks the Securities and Exchange Commission for its assistance in this matter.

Jeremy Christianson and Christopher Beatty from the CFTCís Office of Data and Technology also provided assistance in this matter.

CFTC Division of Enforcement staff members responsible for this action are Harry E. Wedewer, Trevor Kokal, Candice Aloisi, Lenel Hickson, Jr., and Manal M. Sultan.

Media Contact
Dennis Holden
202-418-5088

Last Updated: February 12, 2018


CFTC Orders AMP Global Clearing LLC to Pay $100,000 for Supervision Failures Related to Cybersecurity of its Customers? Records and Information


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