FTC Safeguards Rule Compliance Services

The Federal Trade Commission (FTC) Safeguards Rule requires non-banking financial institutions to develop, implement and maintain an information security program with safeguards designed to protect customer information, all by June 9, 2023. Kroll’s Cyber Risk team has the service capabilities to help your organization tackle the FTC Safeguards Rule line-by-line.

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What is the FTC Safeguards Rule Update?

While the FTC Safeguards Rule isn’t new (It was originally released in 2003.), it did receive substantial updates in 2021. These updates were designed to help covered organizations keep up with the rapid evolution of modern technology. The original deadline for FTC Safeguards Rule compliance was December 9, 2022. However, the final deadline was extended by six months in the latest FTC Safeguards Rule update, and as of now, the deadline for FTC Safeguards Rule compliance is June 9, 2023. 

What Does the New FTC Safeguards Rule Require? 

According to the FTC’s Safeguards Rule Information Page:  

“The Safeguards Rule applies to financial institutions subject to the FTC’s jurisdiction and that aren’t subject to the enforcement authority of another regulator under section 505 of the Gramm-Leach-Bliley Act, 15 U.S.C. § 6805. According to Section 314.1(b), an entity is a “financial institution” if it’s engaged in an activity that is “financial in nature” or is “incidental to such financial activities as described in section 4(k) of the Bank Holding Company Act of 1956, 12 U.S.C § 1843(k).” 

How do you know if your business is a financial institution subject to the Safeguards Rule? First, consider that the Rule defines “financial institution” in a way that’s broader than how people may use that phrase in conversation. Furthermore, what matters are the types of activities your business undertakes, not how you or others categorize your company.” 


Simply put, if you are an organization that handles customer financial data, but aren’t a bank, you are probably covered by the FTC Safeguards Rule and must show compliance to avoid business disruption and fines.


Meet FTC Safeguards Rule Compliance Requirements and Increase Cyber Resilience with a Cyber Risk Retainer

Kroll delivers more than a typical incident response retainer—secure a true cyber risk retainer with elite digital forensics and incident response capabilities and maximum flexibility for proactive and notification services. 

Kroll retainers not only include mandatory compliance services like risk assessments and penetration testing, but also meets practical security needs like cloud security, tabletop exercises, and in the event of an incident, prioritized support.

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How Can Kroll Help?

Kroll has built the foundation and experience needed to handle any size of engagement, including for the world’s top companies in industries from media and entertainment to critical infrastructure. 

We’ve developed a seasoned in-house team dedicated to providing you with the structure and management background needed to scale and adapt your FTC Safeguards Rule compliance program based on your business drivers.

Kroll also boasts a unique advantage: the insights provided by our world-class incident response practice, which feed our certified cyber experts the information they need to test against the exploits attackers are executing today.


Kroll understands that every organization has its own unique needs. This is why Kroll offers three different FTC Safeguards bundles, achieving the “right sized” offering for every organization that needs to satisfy the requirements. 

Kroll’s “Right Sized” FTC Safeguards Rule Compliance Bundles  

Kroll’s FTC Safeguards Rule bundles are built to take the pain and confusion out of this new set of requirements. By offering three different levels of engagement, Kroll enables covered organizations to achieve compliance with a package that fits their needs. 

If your organization handles customer financial information, then you are likely to be covered under the FTC Safeguards Rule. Thanks to Kroll’s extensive background in compliance and financial engagements along with our deep expertise in cybersecurity and IT compliance frameworks, we have the scalable solution for your organization. 


The Support Bundle

The Guide Bundle

The Manage Bundle

For organizations that choose to achieve compliance with FTC Safeguards requirements in-house but require some support.


  • Rapid risk assessment

  • Incident response plan review

  • External penetration test

For organizations that require additional guidance and services to comply with FTC Safeguards requirements.


  • Cyber risk assessment  

  • External penetration test  

  • Incident response plan review 

  • Vendor risk management program

For organizations that require substantial guidance and managed services to comply with FTC Safeguards requirements.

Includes Guide Bundle Services and:

  • Oversight by an experienced vCISO over requirements such as, 

    • encryption

    • asset inventory

    • access control

  • Policy and procedure development

  • Security Culture as a Service (SCaaS)

  • Internal vulnerability scan

What Our Team Brings to the Table


100,000+ Hours of Security Testing and Assessment Work Every Year

Kroll has extensive experience with industry and compliance standards such as NIST, GDPR, CCPA, CMMC, and many others.


100+ Security Certifications across Cyber Risk, Privacy, Offensive Security, Cloud and Hybrid Systems

Our team brings the depth and breadth of expertise needed to tackle complex challenges across a variety of financial services' needs.


3,000+ Incident Response Cases Handled Worldwide Every Year

Kroll's DNA as incident response leader expands our assessments beyond compliance mandates but on actionable remediation based on frontline threat intelligence.

FTC Safeguards Rule Compliance

Talk to a Kroll Expert

Kroll is ready to help, 24x7. Use the links on this page to explore our services further or speak to a Kroll expert today via our 24x7 cyber hotlines or our contact page. 

Our Team

Connect With Us

Keith Novak
Keith L Novak
Managing Director
Cyber Risk
New York
Gregory Michaels
Greg Michaels
Managing Director and Global Head of Proactive Services
Cyber Risk
Samuel Jacobs is Associate Managing Director with the Cyber Risk practice of Kroll, a division of Duff & Phelps, based in Washington, D.C.
Samuel P. Jacobs
Managing Director
Cyber Risk
Washington D.C.

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