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Top 10 Issues General Counsel Need to Know About Ransomware in 2024

Threat actors are evolving. Our Privacy, Cyber & Data Strategy Team explains how ransomware gangs have changed their tactics and how companies can respond to the threat while navigating new scrutiny from investors and...more

FBI and CISA Warn of Chinese Cyberattacks on U.S. Critical Infrastructure

Recently, there has been a surge in alerts and warnings concerning cyberattacks by People’s Republic of China (PRC) state-sponsored threat actors on U.S. critical infrastructure. On February 7, 2024, the Federal Bureau of...more

NYDFS Releases Consent Order in First Enforcement Action Brought Under the Cybersecurity Regulations

After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s...more

NYDFS Finalizes Second Amendment to Its Cybersecurity Regulation

Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more

FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions

On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more

NY DFS Releases Revised Proposed Second Amendment of its Cybersecurity Regulation

The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more

SEC’s Proposed Cybersecurity Rules Delayed Yet Again

On June 13, 2023, the Securities and Exchange Commission (“SEC”) published its Spring 2023 rulemaking agenda that delayed finalizing the proposed Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure...more

NYDFS Penalizes bitFlyer $1.2 Million for Violations to Cybersecurity Regulation

On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more

NYDFS Releases Significant Enhancements to its Cybersecurity Regulation in the Proposed Second Amendment

The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022....more

NYDFS Announces Significant Cybersecurity Settlement with EyeMed Vision Care

On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic...more

CSBS Releases Cybersecurity Programs to Help Nonbank Financial Services Institutions Improve Cybersecurity Posture

On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help prepare for state cybersecurity exams and, ultimately, improve...more

CFPB and FTC Looking to Ramp Up Data Security Requirements

Enhancing data security programs to protect personal information is a critical area companies cannot ignore. Our Privacy, Cyber & Data Strategy and Financial Services & Products groups unpack the latest moves by the Consumer...more

China’s Initial Draft Regulations on the Management of Online Data Security: Important Takeaways

On November 14, 2021, the Cyberspace Administration of China (CAC) released draft Regulations on the Management of Online Data Security (the “Regulations”) for China’s data privacy and security laws, including the...more

Key Takeaways from OFAC’s Updated Ransomware Advisory

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” While this advisory...more

U.S. and Allies Formally Accuse China of Microsoft Hack and Cyberespionage

On July 19, 2021, the Biden administration, along with a group of allies publicly accused the Chinese government of malicious cyber activities and irresponsible state behavior.  The joint announcement states the U.S....more

NYDFS Issues Guidance on Cybersecurity Controls to Combat Ransomware and Clarifies Reporting Obligations

The New York Department of Financial Services (NYDFS) issued new guidance this week intended to assist organizations in thwarting ransomware attacks. The guidance clarifies the NYDFS’ expectation that NYDFS-regulated...more

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