On January 5, 2024, the New York Attorney General’s Office (“NY AG”) announced a settlement with Refuah Health Center, Inc. (“Refuah”) based on the company’s alleged failures to appropriately safeguard its patients’ information, including failing to encrypt patient information or use multifactor authentication, which allegedly resulted in a May 2021 ransomware attack that impacted approximately […]
Cyber Risk
FBI Cautions Organizations on Dual Ransomware Attacks
The Federal Bureau of Investigation (FBI) issued a Private Industry Notification on September 27, 2023, highlighting two concerning ransomware trends and providing companies with guidance on mitigating potential threat actor activity. As of July 2023, the FBI observed multiple ransomware attacks where two attacks against the same victim involving different ransomware variants are deployed often […]
CISA Releases Advisory Concerning Chinese-Backed Threat Actor
On September 27, 2023, The U.S. National Security Agency (NSA), the U.S. Federal Bureau of Investigation (FBI), the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the Japanese National Police Agency (NPA), and the Japanese National Center of Incident Readiness and Strategy for Cybersecurity (NISC) released a joint cybersecurity advisory (CSA) concerning the recent activity of […]
California Proposes Annual Audits to Assess Sufficiency and Compliance of Company Cybersecurity
In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”). Importantly, the proposed regulations set forth more detailed obligations for company cybersecurity programs, including routinely assessing and filing audits with the CPPA. Though these draft […]
NYDFS Penalizes bitFlyer $1.2 Million for Violations to Cybersecurity Regulation
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure to conduct periodic risk assessments to sufficiently inform the design of bitFlyer’s cybersecurity program (as required by 23 NYCRR § 500.09(a)). BitFlyer […]