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Kim Peretti

CISA Revives CIRCIA Rulemaking

March 2, 2026 By Kim Peretti, Lance Taubin and Scott Hilsen

Almost two years after seeking stakeholder input about a final rule under the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA), the Cybersecurity and Infrastructure Security Agency (CISA) announced that it will hold virtual town hall meetings for certain industry sectors in March and April 2026 to solicit additional input on the Notice […]

Filed Under: Board Governance & Cyber Risk Management, Crisis & Data Breach Response, National Security & Digital Crimes, Privacy & Cyber Regulatory Enforcement Tagged With: CIRCIA, CISA, Cybersecurity, Regulatory Enforcement

FBI Launches Operation Winter SHIELD in Effort to Advance Cyber Resilience Across Critical Sectors

February 4, 2026 By Kim Peretti, Lance Taubin and Andrew Rice

On January 28, 2026, the Federal Bureau of Investigation (FBI) announced the launch of Operation Winter SHIELD, a coordinated initiative designed to promote adoption of core defensive measures that are shown to mitigate common intrusion vectors. Operation Winter SHIELD identifies ten priority actions the FBI views as important in improving organizational cyber resilience. The FBI […]

Filed Under: Crisis & Data Breach Response, National Security & Digital Crimes, Privacy & Cyber Regulatory Enforcement Tagged With: Cyber defenses, Cybersecurity, Federal Bureau of Investigation (FBI), National Security

New York Regulates Large Artificial Intelligence Models

January 21, 2026 By Kim Peretti, Jennifer Everett, Scott Hilsen, Dorian Simmons and Santi Villar

On December 19, 2025, just eight days after President Trump issued an executive order titled “Ensuring a National Policy Framework for Artificial Intelligence” to challenge burdensome state laws that regulate artificial intelligence (the “December 2025 EO”), New York Governor Kathy Hochul signed the Responsible Artificial Intelligence (“AI”) Safety and Education Act (the “RAISE Act”). The […]

Filed Under: AI Cybersecurity & Privacy, Artificial Intelligence (AI), Board Governance & Cyber Risk Management Tagged With: Artificial Intelligence, New York, US State Law

DOJ Cybersecurity Enforcement Pace Shows No Signs of Slowing Down Going Into 2026

January 20, 2026 By Kim Peretti, Andrew Liebler, Lance Taubin and Andrew Rice

As 2025 drew to a close, the United States Department of Justice (DOJ) announced significant developments in cases relating to the allegedly deficient cybersecurity practices of two Department of Defense (DoD) contractors. These two cases suggest that the federal government will continue to make DFARS 7012 compliance for companies that process Controlled Unclassified Information (CUI) […]

Filed Under: National Security & Digital Crimes, Privacy & Cyber Regulatory Enforcement Tagged With: Cybersecurity, Defense Federal Acquisition Regulation Supplement (DFARS), Department of Defense, FCA

NYDFS Releases New Prescriptive FAQs on MFA

December 22, 2025 By Kim Peretti, Kate Hanniford, Lance Taubin and Carson Kuck

The New York Department of Financial Services (NYDFS) has released a new set of Frequently Asked Questions (FAQs 18–23) under 23 NYCRR Part 500, reinforcing its position that multifactor authentication (MFA) remains a critical component of a covered entity’s cybersecurity program. These FAQs provide highly prescriptive guidance, including clarifications on technical requirements for the “possession” […]

Filed Under: Privacy & Cyber Regulatory Enforcement

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