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 […]
Connecticut Court Issues First Prompt Injection Sanctions
A Connecticut pro se plaintiff has been caught—and sanctioned for—attempting to manipulate a court he believed was relying on an Artificial Intelligence tool to reach decisions by hiding instructions directed to the tool in court filings. The court held that the plaintiff’s attempted use of an AI “prompt injection” attack offended the integrity of the […]
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 […]
Five Eyes Issues Urgent Call to Action on AI-Driven Cyber Threats
On June 22, 2026, the intelligence alliance known as Five Eyes released a statement warning that frontier AI models will fundamentally transform offensive and defensive cyber capabilities, and that the timeline for this transformation is measured in months, not years. Five Eyes is an intelligence alliance comprising Australia, Canada, New Zealand, the United Kingdom, and […]