---
title: "Best VPN for Financial Services: Safeguards Rule"
description: "The FTC Safeguards Rule asks for encryption in transit and multi-factor sign-in, not a product. See what it requires of a small firm and which VPN plans include the controls."
url: "https://www.vpn.com/vpn/best-vpn-for-financial-services/"
lang: "en"
updated: 2026-11-05
---

> **Bottom Line:** The FTC Safeguards Rule does not require a financial firm to buy a VPN. It requires encryption of customer information in transit over external networks and multi-factor sign-in for anyone using an information system, and a VPN can support both. A VPN alone does not make a firm compliant. The plans below differ on dedicated IP, single sign-on and multi-factor controls.

## What this page is for

This page is for an owner or compliance lead at a small financial firm choosing a business VPN. It sits under our [best VPN for business](https://www.vpn.com/vpn/best-vpn-for-business/) guide, which explains how a business VPN differs from a personal one. For larger organisations see the [enterprise VPN guide](https://www.vpn.com/vpn/best-vpn-for-business/enterprise/). Other regulated fields have different rules; see [best VPN for law firms](https://www.vpn.com/vpn/best-vpn-for-law-firms/), [best VPN for healthcare](https://www.vpn.com/vpn/best-vpn-for-healthcare/) and [best VPN for MSPs](https://www.vpn.com/vpn/best-vpn-for-msps/).

We do not run our own security tests. Every vendor-specific line below is what the vendor says on its own pages, with the date we read it. The rules are linked under Resources. This is general information, not legal advice.

## Does the Safeguards Rule require a VPN?

No. Section 314.4(c)(3) asks for encryption of customer information in transit over external networks, and a VPN is one way to do that for staff on home or public networks. Section 314.4(c)(5) asks for multi-factor authentication for any individual accessing any information system. Neither names a product. A VPN alone does not make a firm compliant, because the Rule is a written programme with a designated Qualified Individual, a risk assessment, vendor oversight and more.

## What a VPN covers and what it does not

| Safeguards Rule item | What it asks | Does a VPN help? |
|---|---|---|
| Encryption in transit, 314.4(c)(3) | Encrypt customer information over external networks | Yes, for traffic through the VPN |
| Encryption at rest, 314.4(c)(3) | Encrypt stored customer information | No. This is disk and database encryption |
| Multi-factor sign-in, 314.4(c)(5) | MFA for any individual accessing any information system | Only if the plan enforces MFA or connects to your SSO |
| Access control, 314.4(c)(1) | Only authorized users, limited to what they need | Partly: an admin console that adds and removes people and restricts which systems each can reach |
| Monitoring, 314.4(c)(8) | Log and monitor authorized users’ activity | Partly: connection logs can feed it |
| Vendor oversight, 314.4(f) | Choose capable providers, contract for safeguards, review them | No. This is your process for any vendor, including the VPN company |

## Is a consumer VPN enough for a small firm?

A fair question: a firm of three to ten people may wonder whether a consumer plan covering that many devices would be enough. It can cover encryption in transit, which is the part a VPN does. The Rule sets no seat floor, and a firm under 5,000 consumers is exempt from four parts of 314.4. It is not exempt from multi-factor sign-in, access control or vendor oversight, and that is where a per-person consumer plan is thin: it has no admin console to remove a leaver’s access, and its terms are not written for a firm’s vendor contract. If you hold customer information, a business plan gives you more to show a regulator.

## Private funds and deal teams

An investment adviser to private funds follows a different text from the Safeguards Rule. The SEC's [Regulation S-P](https://www.sec.gov/files/rules/final/2024/34-100155.pdf) covers broker-dealers, investment companies, funding portals, transfer agents and investment advisers registered with the SEC. The SEC's release notes that the private fund vehicles themselves, such as funds relying on section 3(c)(1) or 3(c)(7) of the Investment Company Act, are not subject to it. The registered adviser is. Whether a particular adviser or fund is covered is a question for counsel.

The SEC [adopted amendments on 16 May 2024](https://www.sec.gov/newsroom/press-releases/2024-58). They require a covered firm to keep written policies for an incident response program "reasonably designed to detect, respond to, and recover from unauthorized access", and to notify individuals whose sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization, as soon as practicable and not later than 30 days after the firm becomes aware of the incident (with limited exceptions). The release also requires policies reasonably designed to make sure service providers protect customer information and tell the firm of a breach as soon as possible, and no later than 72 hours after they become aware of it.

| Item | What the SEC says | Does a VPN help? |
|---|---|---|
| Written safeguards and incident response | Policies and procedures for an incident response program | No. This is your written programme |
| Customer notice | When sensitive customer information is, or is likely to have been, accessed without authorization: as soon as practicable, not later than 30 days after awareness | No. This is a process |
| Service provider oversight | Policies reasonably designed to make sure providers protect customer information and report a breach within 72 hours | No. It is how you manage any vendor; whether a VPN company counts depends on its access to customer information |
| Staff reaching deal documents or investor records from hotel or airport Wi-Fi | The amendments do not name a VPN | Partly: a VPN encrypts the connection, and the data room or system has its own controls |

The compliance dates were staggered. The SEC's compliance outreach page gives 3 June 2026 for smaller firms, which is 24 months after Federal Register publication. On the same count, larger entities' 18 months ends on 3 December 2025; for a registered adviser, "larger" means $1.5 billion or more in assets under management, per the release. Check which applies to you.

Neither the amendments nor the SEC's release name a VPN or require one. They require safeguards and an incident response programme. A VPN alone does not make an adviser compliant with Regulation S-P. Deal teams that travel are a reasonable reason to buy a business plan with an admin console and MFA, and the tool to ask about is the same set below.

## Controls you can buy, and which plan has them

The controls a firm can switch on are dedicated IP or allow-listing (so a system accepts connections only from the firm’s fixed address), single sign-on (SSO, so access follows your staff accounts) and multi-factor sign-in (MFA, a second proof beyond a password). Each vendor below says what its plans include, read on 8 October 2026.

| Provider | Dedicated IP or static IP | SSO | Price shown per user per month |
|---|---|---|---|
| [NordLayer](https://www.vpn.com/out?partner=nordlayer&placement=use-case-body) | Core and above | Listed | $11 (Core), yearly billing |
| [Proton VPN for Business](https://www.vpn.com/vpn/protonvpn/) | Professional | Professional | From $9.99, appears to assume a multi-year term |
| GoodAccess | Every plan | Premium and Enterprise | $11 (Premium), yearly billing |
| Twingate | Enterprise add-on | Teams (Google); Business (Okta, Entra ID) | $5 (Teams), $10 (Business) |

GoodAccess and Twingate have no review page on VPN.com, so they are not linked internally. NordLayer has no review page either, so [NordLayer](https://www.vpn.com/out?partner=nordlayer&placement=use-case-body) links to its own site through our partner link. We earn a commission if you buy NordLayer through it; that does not change what its pages say.

## What to ask a VPN company before customer information goes through it

Section 314.4(f) means treating the VPN company as a service provider. In practice, ask:

1. **Which security reports or certifications do you hold, and can I see them?** Ask for the report, not just the badge, and check its date.
2. **Is there a written agreement that requires you to keep customer information safe, and who signs it?** The Rule asks for safeguards by contract.
3. **Which controls come with my plan?** Dedicated IP, SSO and MFA enforcement are gated by plan at the vendors above.
4. **What does the vendor log, and for how long?** Your own duty to monitor and log does not end with the vendor’s promise.

## Final Verdict

| If this is your situation | Start with |
|---|---|
| You want a dedicated IP, SSO and MFA on a small-firm budget | NordLayer Core or Proton VPN Professional, as each vendor says. Compare the term you must commit to |
| You want a static IP on every plan and can do without SSO at the lowest tier | GoodAccess, as the vendor says |
| You already run Google or Okta sign-in and want it to gate access | Twingate, as the vendor says; check the static-IP add-on if you need one |
| A regulator or partner names a requirement | Get it in writing and match the plan to it. Your regulator, not this page, decides what counts |

The VPN is one control. Your written programme, devices, training and vendor contracts decide the rest.

## Frequently Asked Questions

### Does the FTC Safeguards Rule require a VPN?
No. Section 314.4(c)(3) requires encryption of customer information in transit over external networks and at rest, and 314.4(c)(5) requires multi-factor authentication. A VPN is one way to meet the in-transit part. A VPN alone does not make a firm compliant.

### Who does the Safeguards Rule apply to?
Financial institutions under the FTC’s jurisdiction: businesses engaged in activities that are financial in nature. The FTC’s guide gives mortgage lenders, payday lenders and tax preparation firms as examples. Banks supervised by the federal banking agencies follow the Interagency Guidelines instead.

### Is a small financial firm exempt from the Safeguards Rule?
Only from parts. A firm holding customer information on fewer than 5,000 consumers is exempt from the written risk assessment, continuous monitoring or penetration testing, the written incident response plan and the annual board report. Encryption, multi-factor sign-in, access controls and vendor oversight still apply.

### What does a VPN cover under the Safeguards Rule?
It encrypts traffic between a device and the VPN while on external networks, which supports the in-transit encryption item. It does not encrypt stored data, replace the written programme or oversee your vendors. A VPN alone does not make a firm compliant.

### Do financial firms need multi-factor sign-in on a VPN?
Section 314.4(c)(5) requires multi-factor authentication for any individual accessing any information system, unless the Qualified Individual approves an equivalent control in writing. NordLayer lists MFA, Proton says it enforces 2FA on its Essentials plan, and GoodAccess says MFA enforcement options differ by plan.

### Why would a financial firm want a dedicated IP address on its VPN?
A dedicated IP gives the firm one fixed address, so a system can be set to accept connections only from it. NordLayer says Core and above can add a dedicated-IP server and IP allow-listing. Whether a given system supports that is a question for its own vendor.

### What does a business VPN cost a small financial firm per person?
At the vendors we read on 8 October 2026, list prices ran from $5 to $11 per user per month on the plans in the table. NordLayer lists $11 for Core on yearly billing, and a dedicated-IP server is an extra monthly fee. Seat minimums and billing terms differ, so check each vendor.

### Is a VPN enough to protect customer information?
No. A VPN protects the connection, not the device, the password or the people. The Rule also asks for access controls, logging, training, vendor oversight and, for most firms, a written risk assessment. A VPN alone does not make a firm compliant.

### What should a firm ask a VPN company before customer information goes through it?
Ask which security reports it holds and whether you can see them, whether a written agreement requires it to keep customer information safe and who signs it, which controls your plan includes, and what it logs. Section 314.4(f) asks for vendor oversight.

### Can a financial adviser use a consumer VPN for client work?
A consumer VPN may protect a connection, but it is sold per person and has no admin console to remove a leaver. The Rule sets no seat floor, so a small firm can meet the in-transit part with a multi-device plan; multi-factor sign-in, access control and vendor oversight are where a business plan helps.

### Does Regulation S-P require a VPN for a private fund adviser?
No. The SEC's Regulation S-P, as amended in May 2024, covers registered investment advisers and requires written safeguards, an incident response programme, customer notice and service provider oversight. It names no VPN. A VPN alone does not make an adviser compliant.

## Resources

- [SEC: Regulation S-P final rule, Release No. 34-100155 (16 May 2024)](https://www.sec.gov/files/rules/final/2024/34-100155.pdf)
- [SEC press release 2024-58: SEC adopts amendments to Regulation S-P](https://www.sec.gov/newsroom/press-releases/2024-58)
- [SEC compliance outreach: Regulation S-P for small firms](https://www.sec.gov/newsroom/meetings-events/compliance-outreach-regulation-s-p-small-firms)
- [16 CFR Part 314: Safeguards Rule](https://www.ecfr.gov/current/title-16/part-314)
- [16 CFR 314.4: Elements](https://www.ecfr.gov/current/title-16/part-314/section-314.4)
- [16 CFR 314.6: Exceptions](https://www.ecfr.gov/current/title-16/part-314/section-314.6)
- [FTC: Safeguards Rule, what your business needs to know](https://www.ftc.gov/business-guidance/resources/ftc-safeguards-rule-what-your-business-needs-know)
- [Interagency Guidelines Establishing Information Security Standards (12 CFR 364, Appendix B)](https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-364/appendix-Appendix%20B%20to%20Part%20364)
- [NordLayer pricing](https://nordlayer.com/pricing/)