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User’s Guide to DOJ & CISA Rules Implementing Executive Order 14117

Executive Order (EO) 14117 is a national security rule intended to mitigate national security risks posed by threat countries’ access to sensitive personal data and government-related data. The EO directed the U.S....more

Salt Typhoon Cyberattacks: New Federal Cybersecurity Guidelines for Telecoms

U.S. federal agencies, including the Cybersecurity and Infrastructure Security Agency (CISA), National Security Agency (NSA), and Federal Bureau of Investigation (FBI) (in coordination with similar agencies in Australia,...more

DOJ’s Notice of Proposed Rulemaking on Sensitive Personal Data and Government-Related Data

In October 2024, the U.S. Department of Justice (DOJ) issued a 420-page Notice of Proposed Rulemaking (NPRM) to implement Executive Order (EO) 14117, which directed DOJ to issue implementing regulations and directed the U.S....more

‘Tis the Season… for Cybercriminals: A Holiday Reminder for Retailers

As the holiday shopping season kicks into high gear, it also becomes a prime opportunity for cybercriminals to target retailers, their suppliers, and their customers.  As The Hacker News reports, criminal use of artificial...more

It’s Official: Cybersecurity Disclosure Is Coming This Year

The U.S. Securities and Exchange Commission (SEC) adopted final rules on July 26, 2023, requiring public companies to provide current disclosure, within what may be a short time window, about material cybersecurity incidents...more

Cybersecurity Implementation Plan Offers a Roadmap for Cyber Priorities

The Biden Administration recently reaffirmed its continued focus on cybersecurity by announcing an Implementation Plan for the National Cybersecurity Strategy (the Plan). The Plan provides a roadmap covering the policies and...more

Sector-Based Cybersecurity Requirements for Critical Infrastructure, From Our Water Systems to the Skies

Following the release of President Biden’s National Cybersecurity Strategy, Acting National Cyber Director Kemba Walden explained that the Biden Administration is “expecting more” from owners and operators in critical...more

FERC Establishes New Monitoring Requirements for Bulk Electric Systems

In late January, the Federal Energy Regulatory Commission (FERC) published a final rule directing the North American Electric Reliability Corporation (NERC) to develop and submit modified reliability standards for internal...more

The Biden Administration’s National Cybersecurity Strategy: Impact on the Private Sector

“Continued disruptions of critical infrastructure and thefts of personal data make clear that market forces alone have not been enough to drive broad adoption of best practices in cybersecurity and resilience.” National...more

New TSA Rail Cybersecurity Rule Shows Trend Toward Prescriptive Mandates

Background  Critical infrastructure providers confront unique cyber threats. The use of operational technology (OT) introduces risks that arise from, for example, legacy equipment that cannot readily be patched, updated, or...more

President Biden Issues Executive Order Regarding Signals Intelligence Activities, Clearing Way for New Trans-Atlantic Data Privacy...

President Biden issued an executive order (EO) increasing protections and safeguards for personal data subject to signals intelligence activities. It also establishes a redress mechanism for residents of qualifying states who...more

CISA Seeks Input on New Cybersecurity Reporting Requirements

President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The background and contours of CIRCIA are discussed in a previous update. CIRCIA authorizes and...more

SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance

As cybersecurity threats to the private and public sectors increase, the government has continued its efforts to enhance cybersecurity outside of government-controlled systems. On March 9, 2022, the U.S. Securities and...more

Recent Warnings Highlight Need for Enhanced Cybersecurity of Critical Infrastructure

The U.S. government has steadily increased its warnings about malicious cyber activity by Russia and other sophisticated persistent adversaries. Following several warnings from the Federal Bureau of Investigation (FBI) and...more

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