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Kim Peretti

NYDFS Releases New Prescriptive FAQs on MFA

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

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

Key Breach Notification Updates in California and Oklahoma for 2026

October 24, 2025 By Kim Peretti and Alysa Austin

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 […]

Filed Under: Board Governance & Cyber Risk Management, California Privacy & the CCPA, Crisis & Data Breach Response, Privacy & Cyber Regulatory Enforcement Tagged With: California, Data Breach Notification, Oklahoma, US State Law

Government Shutdown Creates Lapse in Cyber Threat Information Sharing

October 23, 2025 By Kim Peretti

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 […]

Filed Under: Uncategorized

United States, International Coalition Issue Joint Warning of Increasing PRC Backed Threat Activity

September 10, 2025 By Kim Peretti, Lance Taubin and Andrew Rice

On August 27, 2025, the Cybersecurity and Infrastructure Security Agency (CISA), in coordination with the National Security Agency (NSA), the Federal Bureau of Investigation (FBI), and the United States Department of Defense Cyber Crime Center (DC3) issued a joint advisory (Advisory) highlighting increased cyber threat activity linked to People’s Republic of China (PRC) affiliated threat […]

Filed Under: Board Governance & Cyber Risk Management, National Security & Digital Crimes Tagged With: China, CISA, Cybercrime, Cybersecurity, Department of Defense, Federal Bureau of Investigation (FBI), International

CISA Gives Itself an Extension for Cyber Incident Reporting Rules

September 10, 2025 By Kim Peretti

The Cybersecurity and Infrastructure Security Agency (CISA) has extended the deadline for it to issue final rules about mandatory incident reporting for critical infrastructure entities.  The original deadline of October 2025 was pushed by six months to May 2026. Under the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA), passed in 2022, critical infrastructure entities […]

Filed Under: Uncategorized

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