Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
Not applicable.
ITEM 1C. Cybersecurity
Risk Management and Strategy
We identify and assess
material risks from cybersecurity threats to our information systems and the information residing in our information systems by monitoring
and evaluating our threat environment on an ongoing basis using various methods including, for example, using manual and automated tools,
subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and threat actors, conducting scans
of the threat environment, and conducting risk assessments.
We manage material risks
from cybersecurity threats to our information systems and the information residing in our information systems through various processes
and procedures, including, depending on the environment, risk assessments, incident detection and response, vulnerability management,
disaster recovery and business continuity plans, internal controls within our accounting and financial reporting functions, encryption
of data, network security controls, access controls, physical security, asset management, systems monitoring, and employee training.
We engage third-party service providers to provide some of the resources used in our information systems and some third-party service
providers have access to information residing in our information systems. With respect to such third parties, we seek to engage reliable,
reputable service providers that maintain cybersecurity programs. Depending on the nature and extent of the services provided, the sensitivity
and quantity of information processed, and the identity of the service provider, our processes may include conducting due diligence on
the cybersecurity practices of such provider and contractually imposing cybersecurity related obligations on the provider.
35
We are not aware of
any risks from cybersecurity threats, including as a result of any cybersecurity incidents, which have materially affected or are reasonably
likely to materially affect AGBA, including our business strategy, results of operations, or financial condition. Refer to “Part
I, Item 1A—Risk Factors—Risks Factor Relating to AGBA’s business—Unexpected network interruptions, security breaches,
cyberattack or computer virus attacks, and failures in AGBA’s information technology systems, could have a material adverse effect
on AGBA’s business, financial condition, and results of operations” in this Form 10-K for additional discussion about cybersecurity-related
risks.
Cybersecurity
Governance
Our Board of Directors
holds oversight responsibility over AGBA’s risk management and strategy, including material risks related to cybersecurity threats.
This oversight is executed directly by our board of directors and through its committees. Our audit committee oversees the management
of AGBA’s major financial risk exposures, the steps management has taken to monitor and control such exposures, and the process
by which risk assessment and management is undertaken and handled, which would include cybersecurity risks, in accordance with its charter.
The audit committee holds regular meetings and receives periodic reports from management regarding risk management, including major financial
risk exposures from cybersecurity threats or incidents.
Within management, the
Group Chief Information Officer of our business units are primarily responsible for assessing and managing our material risks from cybersecurity
threats on a day-to-day basis and keep the senior executive officers informed on a regular basis of the identification, assessment, and
management of cybersecurity risks and of any cybersecurity incidents. Such management personnel have prior experience and training in
managing information systems and cybersecurity matters and participate in ongoing training programs.
As of the date hereof, the Company has not
encountered cybersecurity incidents that the Company believes to have been material to the Company taken as a whole.