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On March 24 2025, the European Commission (EC) adopted the final draft Delegated Regulation setting out Regulatory Technical Standards (RTS) for subcontracting ICT services supporting critical or important functions under the...more
EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as...more
The European Union’s Digital Operational Resilience Act (DORA) came into effect on January 17, 2025. DORA aims to harmonise rules concerning the provision of information and communication technology (ICT) services to...more
After a two-year implementation period, the EU Digital Operational Resilience Act (DORA) takes effect on 17 January 2025. DORA is part of the EU’s Digital Finance Package and aims to strengthen the financial sector’s...more
The EU Digital Operational Resilience Act (“DORA”) is due to apply from 17 January 2025. It is designed to ensure regulated financial entities can withstand and recover from technology issues such as cyber events and...more
On October 16, 2024, the New York State Department of Financial Services (NYDFS) released guidance highlighting the cybersecurity risks associated with artificial intelligence (AI) and how covered entities regulated by NYDFS...more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
Share on Twitter Print Share by Email Share Back to top “The basic idea for covered firms is if you’ve got a breach, then you’ve got to notify. That’s good for investors.” Those were among the remarks that U.S. Securities and...more
The Australian Prudential Regulation Authority (APRA) released Prudential Standard CPS 230 in March 2017. At a glance, the regulation aims to strengthen the cybersecurity resilience and operational risk management of the...more
A major amendment to the New York State Department of Financial Services' cybersecurity regulations establishes affirmative cybersecurity oversight duties and requires companies to report extortion payments to the agency....more
There will be additional compliance obligations and mandatory contractual provisions introduced for financial entities and outsourced IT service providers. The new DORA seeks to strengthen the resilience of financial...more
On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more
Recently, the Federal Reserve Board (Fed) published its annual Cybersecurity and Financial System Resilience report describing measures it has taken to strengthen cybersecurity in the financial services sector, including the...more
On October 27, 2021, the Federal Trade Commission (FTC) announced a newly updated rule under the Gramm-Leach-Bliley Act (GLBA) intended to require financial institutions to strengthen their data security safeguards to protect...more
The New York State Department of Financial Services recently issued recommendations to financial institutions in the aftermath of the SolarWinds cyberattack. In that attack, hackers inserted malware into SolarWinds software...more
Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...more
In December 2019, we published a blog post introducing open banking; here, we provide an update for 2020. To briefly summarize, open banking comprises a set of rules which permit third-party providers (TPPs) of financial...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more
The FDIC and OCC have issued new guidance for banks on heightened cybersecurity risks facing the financial services industry because of increased geopolitical tensions and threats of aggression. The guidance published on...more
March is now here and with it the Cybersecurity Regulation of the New York Department of Financial Services (NYDFS) is now in full force and effect, including requirements relating to Third Party Service Providers (e.g.,...more
Financial institutions regulated by the New York Department of Financial Services (DFS)—referred to in this post as “Covered Entities”—should by now be well familiar with the department’s sweeping cybersecurity regulation, 23...more
On September 4, 2018, the third stage of compliance deadlines under the New York Department of Financial Services’ (DFS) expansive cybersecurity regulation went into effect....more
The New York Department of Financial Services cybersecurity regulation 23 NYCRR 500 (the “Regulation”) came into effect in March 2017 and established four staggered compliance deadlines for its various requirements. By the...more
The ramp-up of cybersecurity regulation, albeit in a patchwork fashion through state-level legislation, has begun. On May 18, 2018, South Carolina enacted the Insurance Data Security Act (Act), becoming the first state to...more