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Financial Services Law Insights and Observations

Treasury Department clarifies “Essential Critical Infrastructure Workforce” for the financial sector

Federal Issues Covid-19 Department of Treasury

Federal Issues

On March 22, the Treasury Department issued a memorandum stating that the financial services sector is a “Critical Infrastructure Sector” pursuant to the Department of Homeland Security’s Cybersecurity and Infrastructure Security (CISA) March 19 guidance. The memorandum provides that the Essential Critical Infrastructure Workforce for the financial services sector includes workers who are needed to: (i) process and maintain systems for processing financial transactions and services (e.g., payment, clearing and settlement services, wholesale funding, insurance services, and capital markets); (ii) provide consumer access to banking and lending services, such as ATMs and movement of currency (e.g., armored cash carriers); and (iii) support financial institutions (e.g., staffing data and security operations centers). It also includes key third party providers who deliver core services.

On March 24, the Secretary of the Treasury Department, Steven Mnuchin released an additional statement addressing essential financial services workers, expressing strong support for the Department of Homeland Security’s CISA guidance.