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 […]
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CISA Gives Itself an Extension for Cyber Incident Reporting Rules
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 […]
Are You Ready For The Department Of Justice’s Bulk Data Transfer Rule?
On July 8, 2025, the Department of Justice (“DOJ”) is set to lift its self-imposed pause on enforcing certain violations of its Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Bulk Data Rule” or “DOJ Rule”), 28 CFR Part 202. The Bulk Data Rule, […]
Additional Cybersecurity Requirements of NYDFS Part 500 Take Effect Today
Today, on May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take effect. Although the Second Amendment was originally adopted in November of 2023, NYDFS established a multi-year rollout of the Second Amendment’s requirements, […]
2025 State Cybersecurity Legislation Focuses on Financial Services
Eight years ago, on March 1, 2017, the New York Department of Financial Services enacted its landmark cybersecurity regulation covering financial services companies, 23 NYCRR Part 500, known as “Part 500.” Part 500 was the first state regulation to enumerate, in great detail, the elements of a cybersecurity program that a covered financial service company […]