News & Analysis as of

NYDFS Financial Services Industry

Orrick, Herrington & Sutcliffe LLP

NYDFS announces $48.5M settlement over anti-money laundering deficiencies

NYDFS Superintendent Harris announced a $48.5 million settlement with a virtual currency trust company on August 7, resolving allegations of anti-money laundering program deficiencies and failures in due diligence related to...more

Alston & Bird

NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict

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Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more

Paul Hastings LLP

NYDFS Urges Covered Entities to Review Security Practices Amidst World Turmoil

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Citing “escalating global conflict,” the New York Department of Financial Services issued an alert on Monday, June 22, 2025, to its regulated covered entities, urging them to be vigilant against potential security threats,...more

Husch Blackwell LLP

Five Things to Know About the New York Buy-Now-Pay-Later Act

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As part of an omnibus 2026 budget bill, New York passed a new law that will broadly govern point-of-sale (POS) installment financing offered to New York residents. The Buy-Now-Pay-Later (BNPL) Act was signed into law in early...more

Cadwalader, Wickersham & Taft LLP

Digital Assets-Focused UCC Amendments Pass New York Legislature

On June 11, 2025, the New York State Senate passed a bill adopting the 2022 Amendments to the Uniform Commercial Code (UCC). The 2022 Amendments have now been passed by both houses of the New York legislature, and can be...more

Fisher Phillips

New Cyber Rules in Effect as of May 1 for NY Financial Firms: 3 Key Compliance Priorities

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New cybersecurity requirements just kicked in for thousands of financial firms operating in New York, and companies need to make sure they have taken action to comply. As of May 1, the latest amendments to the New York...more

Hogan Lovells

NYDFS: Penultimate set of cybersecurity requirements under amended Part 500 take effect May 1, 2025

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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

Alston & Bird

Additional Cybersecurity Requirements of NYDFS Part 500 Take Effect

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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

Hinshaw & Culbertson - Privacy, Cyber & AI...

Are Your Cybersecurity Controls Ready for the New York State Department of Financial Services' Deadlines?

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

Quarles & Brady LLP

New York Cybersecurity Regulation Requires Submission of Compliance Certification or Acknowledgement of Noncompliance Next Week

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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

Davis Wright Tremaine LLP

Deadline Approaching: Covered Entities Must File Certifications of Compliance With Amended NYDFS Cyber Regulation by April 15

In November 2023, the New York Department of Financial Services (NYDFS) issued its second amendment to its "Cybersecurity Requirements for Financial Services Companies (the Cybersecurity Regulation or Part 500). This was the...more

Katten Muchin Rosenman LLP

Privacy, Data and Cybersecurity Quick Clicks | Issue 27

Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Reminder: New York Cybersecurity Reporting Deadline April 15, 2025; New Regulations Effective May 1, 2025

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

Paul Hastings LLP

Daily Financial Regulation Update -- Tuesday March 18, 2025

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March 17, 2025 - Michelle W. Bowman, currently a governor on the Board of Governors of the Federal Reserve System, was nominated to serve as the vice chair of supervision....more

Husch Blackwell LLP

Deadline Ahead: NYDFS Compliance Notifications are due by April 15

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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

Goodwin

2024 Year in Review: Data Privacy and Cybersecurity

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Welcome to the “Data Privacy and Cybersecurity” chapter of our annual report, Consumer Financial Services: 2024 Year in Review. Consumer financial services regulators are taking a keen interest in artificial intelligence...more

Katten Muchin Rosenman LLP

NYDFS Annual Compliance Submissions Due April 15, 2025 and New Compliance Requirements Effective on May 1, 2025

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

Herbert Smith Freehills Kramer

NYDFS Updates Regulated Firms on Upcoming Cyber Requirements

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

Wyrick Robbins Yates & Ponton LLP

Something Old, Something New: Latest NYDFS Cybersecurity Regulation Enforcement Action Emphasizes Policy Implementation, Training,...

The New York State Department of Financial Services recently announced that it has entered into a consent order with PayPal, Inc. for violations of the NYDFS Cybersecurity Regulation. The consent order, under which PayPal has...more

Husch Blackwell LLP

New York Amends its Data Breach Notification Law

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Keypoint: New York has amended its data breach notification law twice in the last 60 days to (1) add a 30-day deadline for notifying affected residents, (2) clarify that covered financial entities must still notify the New...more

Faegre Drinker Biddle & Reath LLP

Lessons from PayPal’s $2 Million Cybersecurity Settlement with the New York State Department of Financial Services

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

Orrick, Herrington & Sutcliffe LLP

NYDFS warns against risks of sentiment-based cryptoassets

Recently, NYDFS published an industry letter to “all virtual currency business entities licensed under 23 NYCRR Part 200 or chartered as limited purpose trust companies under the New York Banking Law,” disclosing that it is...more

Ropes & Gray LLP

2025 Market Outlook: Government Regulators Prioritize Data Protection and Cybersecurity

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In 2024, financial sector regulators prioritized cybersecurity issues impacting financial institutions and the public. Key U.S. federal agencies—including the Securities and Exchange Commission, Federal Trade Commission, and...more

Paul Hastings LLP

State Stablecoin Legislation

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Stablecoins, which are digital assets pegged to fiat currency or other assets, play a crucial role in crypto markets, offering price stability and facilitating transactions. Despite their growing significance, there is no...more

Troutman Pepper Locke

New York Issues Proposed Regulations About Overdraft Fees

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Given the future uncertainty of the Consumer Financial Protection Bureau’s (CFPB) efforts to regulate bank overdraft fees, New York’s Department of Financial Services (DFS) has stepped in to fill a perceived gap. The DFS...more

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