On September 10, 2026, the New York State Department of Financial Services (“NYDFS”) published an Industry Letter (the “Letter”) to regulated entities (“Covered Entities”) addressing what is probably the most frequently asked Part 500 question: “How to Conduct and Use Risk Assessments Required by the DFS Cybersecurity Regulation.” The risk assessment is, by all accounts, […]
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Trump Administration Unveils New Program for Targeting Cyber Criminals
On August 12, 2026, President Trump signed a National Security Presidential Memorandum regarding Expanding Capabilities to Combat Transnational Cyber-Enabled Crime (the “Memorandum”) directing U.S. law enforcement to target and disrupt transnational criminal organizations. To accomplish this goal, the Memorandum establishes a program allowing private sector companies to partner with the government to fight “Cyber-Enabled Transnational […]
IBM’s 2026 Cost of a Data Breach Report Signals a New Era of AI-Driven Cyber Risk
IBM recently released its Cost of a Data Breach Report 2026, which highlights the changing cyber threat landscape in which artificial intelligence (AI) is accelerating how threat actors identify vulnerabilities, launch attacks, and exploit compromised systems. These trends are reflected in rising average breach costs, with the global average cost rising 12% to a record […]
CMMC Phase II is Suspended, but Defense Contractors’ Cybersecurity Obligations are Not
The Department of Defense (“DOD”) has announced the immediate suspension of the Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which were scheduled to take effect on November 10, 2026. This announcement is significant because, as we noted in our prior advisory, Phase II was expected to move CMMC toward more formal assessment requirements for […]
The White House’s Gold Eagle Initiative Signals a New Phase in AI Enabled Cyber Defense
The White House has launched “Gold Eagle,” a new cybersecurity vulnerability coordination clearinghouse designed to use advanced AI capabilities to accelerate how the government and industry identify, prioritize, verify, and remediate software vulnerabilities. The initiative was established under the June 2, 2026 Executive Order, “Promoting Advanced Artificial Intelligence Innovation and Security,” and is being framed […]