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The Financial Stability Board (FSB) has published its finalised Format for Incident Reporting Exchange (FIRE), together with a press release and updated webpage. FIRE provides a standardised format for financial institutions...more
On January 15, 2025, the FAR Council finally released a proposed rule (the Rule)1 regulating the use and handling of controlled unclassified information (CUI) as a part of the general strategy to reduce threats of...more
On January 14, the UK government published a consultation on new measures to tackle the increasing threat of ransomware attacks. Ransomware is malicious software (malware) that infects a victim’s computer system and prevents...more
On January 15, 2025, the Federal Acquisition Regulation (“FAR”) Council issued its long-awaited “CUI Rule.” CUI, or Controlled Unclassified Information, is information that the government creates or possesses, or that an...more
As cybersecurity rules proliferate, companies must navigate a maze of new, and often overlapping, proactive and reactive cybersecurity requirements and guidance. This Legal Update surveys new cybersecurity rules and...more
As discussed in our previous blog post, the Cybersecurity and Infrastructure Security Agency (CISA) is proposing a significant new rule to bolster the nation’s cyber defenses through mandatory incident reporting. While...more
On May 23, 2024, the U.S. Department of Housing and Urban Development (“HUD”) issued requirements, effective immediately, for all FHA-approved mortgagees to report certain cyber incidents to HUD within 12 hours of detection....more
For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...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
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
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
On March 11, the Governor of Indiana signed SB 220 (the “Act”) which will add cyber incident notification guidelines for financial institutions. The Act defined the term "corporation" as the following entities organized in...more
On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...more
The date July 26, 2023, marks the latest evolution of the cybersecurity regulation landscape as the Securities and Exchange Commission passed cybersecurity regulations for publicly traded companies. At the open meeting, SEC...more
Texas recently amended its breach notification statute to shorten the time businesses have to notify the state Attorney General after a data breach affecting 250 or more Texas residents. As of September 1, businesses must...more
Boards of Directors for public companies across the country are likely to be taking stock of their companys’ cybersecurity practices and strategies after the Securities and Exchange Commission’s adoption of the Cybersecurity...more
On July 26, the Securities and Exchange Commission (“SEC”) finalized a much anticipated rule addressing cybersecurity risk management, strategy, governance, and incident disclosure. Public companies registered with the SEC...more
At an Open Meeting on July 26, 2023, the US Securities and Exchange Commission (SEC) adopted final rules and amendments that impose new cybersecurity-related disclosure requirements for public companies subject to the...more
In yet another indication of the increasing weight being given by government officials to cybersecurity, on July 26, 2023, the Securities and Exchange Commission adopted new rules requiring public companies to disclose...more
Three days. Starting September 1, 2023, that is all federally insured credit unions will have to report cyber incidents. The rule, approved on February 16, 2023, broadly defines cyber incident to include any incident that...more
In May 2021, Colonial Pipeline, a privately held oil pipeline responsible for nearly half of the oil supply for the U.S. East Coast, was crippled by a DarkSide ransomware attack. DarkSide is widely believed to be a...more
On January 26, 2023, the Department of Justice announced its successful “months-long disruption campaign” against a ransomware group known as Hive, signaling the United States’ increased efforts to combat ransomware attacks...more
Welcome to 2023. As in 2022, we are likely to see continuing escalation of cyber intrusion threats to healthcare entities – and their data. Healthcare data breach already is far from a trivial matter – according to one...more
Cyberattacks continue to plague businesses, making the fallout of data breach notification and response as critical as ever. This year, like 2021, has been relatively quiet as it relates to state updates to breach...more
The federal Cybersecurity & Infrastructure Security Agency (CISA) has issued a request for information (RFI) seeking public input on its development of cyber incident and ransom payment reporting rules under the Cyber...more