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Incoming DFS Chief Calls Cyber the “Number One Threat” Facing Industry and Government

The incoming chief of New York’s top financial services regulator called cybersecurity “the number one threat facing all industries and governments globally” during a speech on Friday, April 12, 2019 at the Association of the...more

A Shield From Cyber Liability: Integrating SAFETY Act Protections Into Institutional Cyber Governance

An obscure federal law called the SAFETY Act recently captured national headlines when MGM Resorts International invoked it in a series of pre-emptive, declaratory judgment law suits against the victims of the 2017 Route 91...more

In Warning Shot to Foreign Hackers, U.S. Indicts Two Iranian Nationals for Massive Ransomware Attacks

Yesterday, the United States indicted two Iranian hackers for their roles in a series of major ransomware attacks that started in 2016 and lasted almost three years. The attacks crippled schools, hospitals, the private...more

In Search of Immunity: MGM Fights to Define SAFETY Act Protection

Memories of the massacre of dozens of concertgoers at a Las Vegas music festival last year are unlikely to fade soon. In the deadliest shooting in U.S. history, Stephen Paddock killed 58 people and wounded hundreds from his...more

California’s New Digital Privacy Law: Impact on Business Operations

California’s landmark digital privacy law – enacted less than two weeks ago – is the most sweeping consumer data protection law in the United States. The California Consumer Privacy Act of 2018, or CCPA, will apply to more...more

Another DFS Cyber Deadline Looms

For thousands of financial institutions and insurance companies covered by New York DFS’s sweeping data security regulation, the countdown to yet another deadline has begun. Those companies will remember last August, when...more

The New York Department of Financial Services Issues Its Final Cybersecurity Regulation

On February 16, 2017, the New York Department of Financial Services (“DFS”) issued the final version of its cybersecurity regulation. The regulation, which has seen several iterations since it was first proposed in September...more

DFS Final Cyber Regulation: Accountability at the Top

Over the last few months, the New York Department of Financial Services (“DFS”) cybersecurity regulation has undergone multiple revisions. But late last week, DFS issued its final regulation, which will go into effect on...more

Final DFS Cybersecurity Regulation Issued

New York’s Department of Financial Services issued its final Cybersecurity Regulation last night with an effective date of March 1, 2017. ...more

Rock and a Hard Place: Banks In Search of Compliance Amid Diverging Regulatory Regimes

Last year was the first that national banks and federal savings associations subject to supervision by the Office of the Comptroller of the Currency (“OCC”) were armed with a sense of the agency’s regulatory expectations when...more

Law Firms and Vendors Mandated to Up Their Cyber Game: Final Installment in a 3-Part Series

This is our final installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation.  In this installment, we provide an overview of the regulation’s impact...more

Cyber Regulation Demands Board Accountability: Part 2 in a 3-Part Series

This is our second installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation. In this installment, we provide an overview of the regulation’s impact...more

Unpacking New York’s Cybersecurity Regulation: Part 1 in a 3-Part Series

This is the first installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation. The Patterson Belknap Privacy and Data Security Team has studied the...more

Cyber in the Board Room: Balancing Risk and Oversight

Boards of directors remain increasingly exposed to the threat of liability arising from data breaches and other cyber-incidents. Nearly a year ago, Senators Jack Reed and Susan Collins introduced the Cybersecurity...more

OCC’s Cybersecurity Regulatory Expectations: A Call to Action

Not surprisingly, cybersecurity remains a top examination priority for the Comptroller of the Currency (“OCC”). And that means national banks and federal savings associations – and their leadership teams – should be prepared...more

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