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After years of regulatory uncertainty, the Trump administration has signaled a new approach to digital assets, including by establishing a working group focused on digital assets and nominating crypto-friendly chairs to the...more
Businesses that are subject to the NYDFS Cybersecurity Regulations have four weeks left to submit their annual notices of compliance or acknowledge their noncompliance. When the regulations were amended in 2023, several of...more
As we previously reported, in 2023 the New York State Department of Financial Services (NYDFS) amended its cybersecurity regulation, 23 NYCRR 500 (or Part 500). As of November 1, 2024, Class A Companies and Covered Entities...more
Financial firms doing business in New York should be mindful of a recent e-blast sent by the state’s financial regulator concerning cybersecurity requirements that become effective in less than two months. The New York...more
On January 23, 2025, PayPal settled an enforcement action brought by the New York State Department of Financial Services (NY DFS) for failing to comply with cybersecurity regulations required for financial services businesses...more
In December 2024, New York Governor Kathy Hochul signed into law two bills (A8872A and S2376B; collectively, the “Bills”) that amend New York’s Data Breach Notification Law. The Bills introduce a maximum thirty-day timeframe...more
Remote worker fraud is expected to continue to proliferate in 2025. Fully remote hiring and work, particularly in the technology sector, continues to pose unique business and legal risks for companies. Just in December 2024,...more
The New York Department of Financial Services (NYDFS) issued new guidance (the Guidance) on October 16, 2024, to help state-regulated financial institutions mitigate the myriads of cybersecurity risks posed by artificial...more
Cyber, Privacy, and Technology Report - Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed....more
In this month’s Privacy & Cybersecurity Update, we examine the newly established data privacy framework between the EU and U.S. and new consumer privacy laws in Oregon and Texas. We also review a court ruling that delayed...more
The year 2022 saw a groundswell of interest in privacy rights and related legislation. Five states enacted new laws or regulations aimed at protecting a general right to privacy, while the U.S. government came closer than...more
Companies should take note of two imminent developments in New York in the area of cybersecurity regulation: enforcement of the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (Regulation) and the...more
Department of Homeland Security Warns of Cyber-Attacks by Iran - The Department of Homeland Security (DHS) issued a grave warning to U.S. businesses and critical infrastructure operators on January 6, 2020, alerting the...more
On September 1, 2018, five new requirements included in the New York State Department of Financial Services’ (DFS) Cybersecurity Regulation go into effect – (1) audit trails, (2) application security, (3) data disposal...more
Following New York’s lead after the Department of Financial Services (the NYDFS) promulgated its Cybersecurity Regulation, in October 2017 the NAIC adopted its Insurance Data Security Model Law (the NAIC Model) to establish...more
As of February 15, 2018, banks, insurance companies, and other financial services institutions and licensees regulated by the New York Department of Financial Services (DFS) are required to file their first certification of...more
The Consumer Financial Protection Bureau (CFPB), one of the watchdogs of the financial services industry, has announced through Acting Director Mick Mulvaney that it will no longer collect personal information of consumers...more
Updates on the EU: German DPA Publishes First Privacy Shield Guidelines, Requires German-Law Contracts for Transfers. On June 7, 2016, the European Commission adopted the EU-U.S. Privacy Shield. One question that many...more