Primary regulators
SEC · FINRA · State securities administrators
Whatever your firm does, your most valuable assets have migrated inside your technology. Client money. Client trust. Decades of proprietary work. Patient records. The decisions, the relationships, the institutional knowledge that took years to build — all of it now travels through platforms, tenants, and systems that most firms set up once and never revisit. The seven industries below represent the specific regulatory obligations and operational risks we build to. But the underlying stakes are the same: what's inside your technology is worth protecting as carefully as what's on your balance sheet.
The list below is what every Twin Networks engagement delivers, regardless of sector. The seven sections that follow add the specific obligations and idioms of each industry on top of it.
An RIA with $500M under management often runs on the same Microsoft 365 tenant as a marketing agency — and has a regulator who asks why. The good news: the gap between "it works" and "it stands up to an SEC exam" is a finite, knowable distance, and we've walked it with firms like yours before. Reg S-P, Reg S-ID, books-and-records preservation, marketing-rule archiving, advisor supervision — encoded into the architecture so your compliance team can focus on judgment, not reconciliation.
A client needed OFAC sanctions screening. Nothing on the market fit. So we built one — integrated directly into the workflow they already ran, with the logging and exception handling their compliance process needed.
This is the line between a commodity MSP and a technology partner. When the right solution doesn't exist, we don't sell you the wrong one — we build the one you needed.
Your clients' retirement. Their children's tuition. The generational wealth transfer they're trusting you to manage. That trust now travels through email, CRM notes, portfolio systems, and text messages — and the SEC expects every channel to be governed, preserved, and retrievable on demand.
The firms that get examined well aren't the ones with the thickest binders. They're the ones whose technology can produce the evidence in fifteen minutes, not fifteen days.
We build the Microsoft 365 tenant to an RIA standard — conditional access, privileged-identity management, audit logging retained beyond default windows. Separately, we deploy a dedicated communications archiving platform (Smarsh or equivalent) that journals email, Teams, and SMS at the moment of transmission into a WORM-compliant or audit-trail-compliant store — so that books-and-records obligations are met by architecture, not by the advisor who remembered to CC their work email. Backup protects the business. Journaling satisfies the regulator. Both are in place, and neither substitutes for the other.
Quarterly, an independent auditor walks the whole environment and writes up what's working, what drifted, and what the SEC would ask about. The report goes to your CCO before it goes to us.
When the exam letter arrives — because it will — the evidence is already compiled. We've sat through SEC examinations with our clients. The Tuesday-afternoon scramble is not the standard; it's the sign something wasn't set up right. The build itself runs on an automated process — every control deployed, verified, and re-verified by runbook — so nothing gets skipped and nothing drifts unseen. Behind it, a 24/7/365 Security Operations Center watches the environment in real time, with anti-ransomware and data-exfiltration controls layered at identity, endpoint, and egress.
Privilege doesn't live in your retainer agreement. It lives in the permission on your document management system, the rule on your email server, the mobile device an attorney left in a rideshare, and the AI tool an associate just pasted a redline into — each one a place where a confidence can leak before anyone realizes it has. ABA Formal Opinions 477R and 498 took "protect your clients" from an ethical aspiration to a concrete technical standard: firms must make "reasonable efforts" to prevent unauthorized access, and that standard now has teeth — bar complaints, malpractice exposure, and Outside Counsel Guidelines that audit your controls before your largest clients will send you work. A concrete standard is something you can meet, measure, and improve on. The firms who approach it that way sleep better, answer client questionnaires in hours, and win engagements the others lose on the security section.
Your matters. Your clients' confidences. The privilege that took decades to build and can be lost in a single misrouted email or an AI prompt that trained on a settlement agreement. And then there are the Outside Counsel Guidelines — every major client now audits your cybersecurity before they'll send you work.
The managing partner's question isn't "are we secure?" It's "can we answer our largest client's security questionnaire truthfully?"
Matter-based access is the foundation. Ethical walls are enforced by the platform — iManage, NetDocuments, or the equivalent — tied into identity, conflict checks, and email rules so the wall is the default, not an exception somebody has to remember.
We build AI governance that says yes to the tools your attorneys want (and will use either way) but contains them: tenant-locked, no-training agreements with the provider, DLP on prompts, matter-segregated retrieval. The rule isn't "no AI." It's "AI that respects privilege."
Every paid tax preparer is now required to have a Written Information Security Plan — IRS Pub 4557, the FTC Safeguards Rule, and state analogs all point to the same discipline. The WISP in a binder on the shelf isn't the finish line; it's the starting line. Turn it into something your technology actively enforces and tax season goes back to being about returns, not incidents. That's the simple, achievable shift we help firms make.
Social security numbers. Dates of birth. Estate plans. Payroll data. Business financials. All of it concentrated in your firm for three months of the year, in tax software designed by engineers who didn't build for your threat model.
And the one thing the IRS won't forgive: a data breach that reveals your WISP was a paper document, not a practice.
We treat your WISP as the source of truth and build the technology to match it. Every control the document promises, we wire into the environment — enforced by policy, logged centrally, reviewed quarterly. When the IRS asks what you do, you can show them, not tell them.
Starting in November, we run a pre-season hardening sprint: MFA verified everywhere, vendor access reviewed, tax software permissions audited, incident runbook refreshed, phishing simulation done while there's still time to train. By January 15 you're not hardening — you're filing.
NY DFS Part 500 redefined the standard. Connecticut, Massachusetts, and twenty-odd other states wrote their own versions modeled on it. Your carriers rolled the same requirements into producer agreements. It sounds like more weight — in practice, a well-run program is lighter than the patchwork most agencies carry today. You stay the decision-maker; we carry the execution and the paperwork.
Your book of business. Your carrier appointments. The E&O exposure that doubles the moment it becomes clear your cyber program was a line item, not a practice. The 72-hour regulatory notification clock that starts the minute your IT vendor calls with bad news.
And the fact that increasingly, your largest carriers will revoke appointments from producers who can't demonstrate a functioning cyber program.
We serve as your named CISO under DFS 500 and its state analogs. Annual certification, board reporting, risk assessment, incident reporting — the officer duties get performed by someone qualified to do them and to sign their name to them.
Between certifications, we keep the program running: tabletop exercises twice a year, vendor risk reviews on a cycle, carrier questionnaires answered with evidence the first time. When the regulator shows up, you already have the book.
A BIM model is an asset. Your clients — especially the government ones — are asking harder questions: ITAR data, export-controlled designs, AIA cybersecurity clauses once optional and now standard. Meet those questions well and they become a competitive advantage on the next pursuit, not a drag on the last one. The firms that treat their design files like the assets they are win the work and keep it.
Design IP that's already been sold to a client but lives on your servers. Specifications under NDA. Renderings that can't leak before a public announcement. And on federal or defense work, technical data that's literally export-controlled — the wrong person forwarding a Revit file overseas is a federal matter, not an IT matter.
The client question that's getting harder to answer honestly: "Where are our files, and who can see them right now?"
We treat design files as the crown jewels of the firm. Access is tiered by project and role. Departure workflows include an IP audit — not just "deactivate the account" but "verify they haven't staged files elsewhere." For defense-adjacent work, we build or broker an ITAR-compliant enclave so export-controlled data doesn't mix with everything else.
Backups are tested against a BIM restore, not a file-count. Because what good is a backup that returns the files but loses the linked libraries that make them usable?
The HIPAA Security Rule hasn't had a significant update since 2013. That changes in 2026. The proposed overhaul — the biggest rewrite in over twenty years — eliminates the distinction between "required" and "addressable" controls, makes MFA and encryption mandatory with no flexibility, and requires continuous risk assessments rather than annual ones. OCR has already launched Phase 3 of its compliance audit program, targeting 50 covered entities and business associates. The direction is clear: the era of flexible, interpret-it-yourself HIPAA compliance is ending. What replaces it is a concrete technical standard — and a concrete standard is something you can meet, measure, and improve on. The practices that position you well for the new rule are the same ones that protect your patients today.
Patient safety. Continuity of care. The ability to keep seeing patients the week after a ransomware event, because the EHR is restorable and the schedule didn't evaporate. And — not incidentally — avoiding the multi-million-dollar settlement that tends to follow an OCR investigation.
The first question OCR asks isn't about the incident. It's: "Let us see your current Security Risk Analysis."
The second question is increasingly: "Show us your AI governance policy." Staff are pasting patient intake notes into ChatGPT, running clinical summaries through Copilot, and uploading discharge documents to tools with no Business Associate Agreement, no data residency controls, and no way to know whether that PHI is training a model somewhere. HIPAA doesn't have an exception for productivity tools your staff started using because nobody said no.
We serve as your Security Officer under the Security Rule and partner with your Privacy Officer on the administrative side. The Security Risk Analysis becomes a living document — updated when anything material changes, and backed by evidence of the controls it references. The difference between the binder on the shelf and actual compliance is technical enforcement: controls that are deployed in the environment, verified on a schedule, and documented in a way the auditor can follow. We build the second. The first is easy to produce once the second exists.
We build AI governance that doesn't just say no. Staff will use productivity tools regardless — the question is whether PHI travels with them when they do. We establish what tools are permitted, negotiate or verify BAAs with providers, configure DLP to flag PHI in AI prompts, and document the governance program so that when OCR asks, the answer isn't "we told staff not to."
We run annual tabletop exercises against the breach notification clock so your leadership knows the process before the real one starts. And we track the proposed Security Rule overhaul so that when it finalizes, your environment is already most of the way there — not starting from zero on a 180-day clock.
The Cybersecurity Maturity Model Certification rule became effective at the end of 2024. Contracting officers are writing CMMC requirements into solicitations; primes are flowing the obligations down to tier-two and tier-three suppliers. Here's the honest part: it's a lift, and it's achievable. The shops who start early, scope smartly, and iterate quarterly are the ones walking into C3PAO assessments with confidence — and walking into the next award cycle with an edge their competitors don't have.
Level 1 — the Federal Contract Information (FCI) floor. Seventeen basic safeguarding practices. Annual self-assessment and affirmation by a senior company official. Required for any contract where your shop handles FCI, which is most of them.
Level 2 — Controlled Unclassified Information (CUI). The full 110 practices of NIST SP 800-171. Audited every three years by an accredited C3PAO, with annual affirmation in between. This is the level most manufacturing subcontractors end up at the moment a prime sends them drawings marked CUI.
Level 3 — the NIST SP 800-172 enhancements on top of Level 2, assessed by DIBCAC itself. Reserved for the most sensitive programs. If you're there, you already know.
We start with scoping. Not every part of your business needs to be in the CMMC boundary — most shouldn't be. Drawing that boundary well is the single most important decision in the program, because it determines what you certify, what you spend, and what you live with operationally.
Then we build the enclave. GCC High for the environments that need it, or a Microsoft 365 GCC High equivalent architecture where that's the right fit. CUI moves out of the general environment and into a controlled space with evidence for every 800-171 practice. We remediate your SPRS score honestly, document the system security plan and plan of action with evidence the C3PAO will accept, and stand with you through the assessment.
On the other side: annual affirmation, continuous monitoring, and the POA&M kept current — because CMMC is not a one-time certification, it's a program you maintain.
A 20-minute call with Chris Brown is how most engagements begin. No pitch deck. No canned assessment. Just a conversation about where your firm is, where you want it to be, and what getting 1% better every quarter looks like — with you firmly in the driver's seat and an expert team carrying the load alongside you.
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