U.S. supply chain security is increasingly under threat. The White House’s National Security Strategy describes this moment as an inflection point. Many federal agencies have taken charge in elevating the very concept of...more
The proliferation of cybersecurity regulations has the White House and Congress calling for harmonization to streamline regulations, focus on reciprocity, and decrease compliance costs. Senator Gary Peters (D-MI), chair of...more
A significant shift in cybersecurity compliance is on the horizon, and businesses need to prepare. Starting in 2024, organizations will face new requirements to report cybersecurity incidents and ransomware payments to the...more
Cyber incidents involving critical infrastructure pose a serious risk to the US. In March 2024, the Environmental Protection Agency and the National Security Advisor warned state governors about potential attacks on drinking...more
On May 7, 2024, the White House Office of the National Cyber Director (ONCD) released several reports on the United States’ cybersecurity posture and strategic plan. These documents implement the 2023 National Cybersecurity...more
Remember CIRCIA? The Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”) – intended to beef up reporting requirements across industries following cyber incursions – is moving along the pathway from...more
In early April, the Cybersecurity & Infrastructure Security Agency (CISA), within the US Department of Homeland Security, released a Notice of Proposed Rulemaking (NPRM) regarding the implementation of the Cyber Incident...more
The Cybersecurity and Infrastructure Agency (CISA) is seeking comment on a proposed rule to implement reporting requirements for critical infrastructure entities, including health care entities, on cyberattacks and ransomware...more
April 2024 On April 4, 2024, the U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (“CISA”) published a 447-page Notice of Proposed Rulemaking (“Proposed Rules”) in accordance with the...more
For years, we were able to tell most clients experiencing a potential data security incident that they likely had at least 30 days to notify any third parties about the incident – if they concluded it was a breach. There...more
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) within the Department of Homeland Security published a long-awaited notice of proposed rulemaking (NPRM) pursuant to the Cyber Incident Reporting...more
On April 4, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published its much-anticipated Notice of Proposed Rule Making for the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA)....more
CISA's proposed rules will require organizations operating in U.S. critical infrastructure sectors to report cyber incidents within 72 hours and ransom payments within 24 hours. ...more
Most businesses in the United States will have to file incident reports—including for ransomware payments—under the Proposed Rule. The Department of Homeland Security has the authority to issue subpoenas and even penalties...more
On March 15, 2022, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 was signed into law. Generally, CIRCIA requires “covered entities,” defined as entities in certain critical infrastructure sectors, to...more
The Cybersecurity and Infrastructure Security Agency (“CISA”) recently released its new Proposed Rule pursuant to the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which was published in the...more
A sweeping array of businesses are another step closer to requirements to report cybersecurity incidents and ransomware payments to the federal government. On April 4, 2024, the U.S. Department of Homeland Security's (DHS)...more
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) published a notice of proposed rulemaking (NPRM) implementing the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA). For...more
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA), an operational component of the Department of Homeland Security (DHS), posted for public inspection its long-anticipated notice of proposed...more
These days, cyber regulators are in a hurry. Commentators have observed, the “federal government is quietly directing a seismic shift in the economy” with new mandates. Ann Neuberger, Deputy National Security Advisor for...more
On March 27, 2024, the Cybersecurity & Infrastructure Security Agency (“CISA”) released proposed regulations requiring expansive new cybersecurity incident and ransomware payment reporting across sixteen “critical...more
As we near the end of another year, it is time to look ahead to developments in the information security and privacy landscape. One area of particular importance is the development of regulations implementing the Cyber...more
Background: In March 2022, President Joe Biden signed the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) into law, ushering in a new era of enhanced cybersecurity measures. This legislation...more
On September 12, 2022, the Cybersecurity and Infrastructure Security Agency (CISA) issued a request for information (RFI) seeking input from stakeholders on the Cyber Incident Reporting for Critical Infrastructure Act of 2022...more
The Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA), signed into law by President Biden in March 2022 as part of the Consolidated Appropriations Act of 2022, will require companies operating in...more