The New York Department of Financial Services (DFS) recently issued guidance to its regulated entities regarding heightened cybersecurity awareness as a result of the COVID-19 pandemic. DFS described three primary areas of heightened risk during this time: remote working, increased instances of phishing and fraud, and third-party risks.

With respect to remote working, DFS noted several areas of risk created by the shift to remote working. The prospect of more remote workers means additional security risks for all businesses. The DFS guidance focused on reminding regulated entities to use secure connections for remote workers – including the use of multi-factor authentication and VPN connections – to use secure wireless devices, and to provide guidance to employees regarding the secure use of wireless devices and other remote video conferencing tools.

DFS noted that there has been a significant increase in online fraud and phishing attempts and stated that the FBI has reported the use of fake emails purporting to be from the Center for Disease Control and Prevention (CDC), looking for charitable contributions or offering COVID-19 relief checks. DFS stated, “Regulated entities should remind their employees to be alert for phishing and fraud emails, and revisit phishing training and testing at the earliest practical opportunity.”

The third area DFS focused on was third-party risks. DFS suggested that regulated entities should coordinate with critical vendors to determine how they are adequately addressing new risks.

Finally, DFS issued a reminder that under 23 NYCRR Section 500.17(a), covered Cybersecurity Events must be reported to DFS as promptly as possible and within 72 hours at the latest.

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