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 […]
DOJ Cybersecurity Enforcement Pace Shows No Signs of Slowing Down Going Into 2026
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) […]
NYDFS Releases New Prescriptive FAQs on MFA
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” […]
Key Breach Notification Updates in California and Oklahoma for 2026
Effective January 1, 2026, new legislation in California and Oklahoma will introduce important updates to each state’s breach notification requirements. These changes may significantly impact breach response obligations for businesses operating in or handling data related to residents of these states. Below is a summary of the key provisions under each law. California – Senate […]
Government Shutdown Creates Lapse in Cyber Threat Information Sharing
The day before the recent federal government shutdown, a ten-year old cybersecurity law expired before it could be reauthorized. The Cybersecurity Information Sharing Act of 2015 (“CISA”) provided a mechanism for private companies to share information with the federal government about cyber threats in return for certain legal protections. CISA applied only when the information […]