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On May 1, 2025, additional cybersecurity requirements introduced by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) took...more
On May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take...more
As part of a multiyear rollout, the New York Department of Financial Services (NYDFS) has established May 1, 2025, and November 1, 2025, as effective dates for certain amendments to its cybersecurity regulations. These...more
Our Privacy, Cyber & Data Strategy Team highlights the increasingly specific cybersecurity controls identified by regulators, explains why these enhanced cybersecurity controls have become the focus of regulators, and shares...more
In November 2023, New York State's Department of Financial Services (NYDFS) amended its cybersecurity regulation, Part 500. This legal alert provides an update for Covered Entities and Class A Businesses on the current NYDFS...more
On April 3, 2025, the New York State Department of Financial Services (“DFS”) issued reminders about upcoming implementation and reporting deadlines related to its cybersecurity regulations. Upcoming deadlines require...more
Covered entities regulated by the New York State Department of Financial Services (NYDFS) must submit cybersecurity compliance forms by April 15, 2025. New sets of requirements for system monitoring and access privileges,...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
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 issued a cybersecurity advisory on November 1, 2024, regarding a growing threat posed by North Korean operatives seeking remote IT roles at U.S. companies. These operatives secure...more
The New York Department of Financial Services (“NYDFS”) recently published guidance on managing cyber risks related to AI for the financial services and insurance industry. Though the circular letter does not introduce any...more
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
On November 1, 2023, the New York State Department of Financial Services (“DFS”) amended its cybersecurity regulations to institute additional standards and controls aimed at securing sensitive data among the financial...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
In the fall of last year, we wrote about the passage of the SHIELD Act (the Act) in New York, which expanded aspects of the state’s breach notification requirements (Breach Requirements) and created a statutory obligation to...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
Time is running out. The effective date of New York’s cybersecurity law mandating that organizations implement an information security program to protect “private information” of New York State residents, including employee...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
In view of Iran’s vows to retaliate against the United States for the death of Quassem Soleimani, the NYDFS has issued an industry letter to all regulated entities regarding the need for heightened cybersecurity precautions....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
The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions. (Here). The NYDFS has filled a vacuum created by the failure of the federal government to act in this...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
Cybersecurity has in recent years become an integral component of a board’s role in risk oversight, but directors often find themselves in unfamiliar territory when it comes to formulating policies and oversight processes...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...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