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 […]
Cyber Risk
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 […]
UK’s National Cyber Security Centre Releases 2022 Annual Review
The United Kingdom’s National Cyber Security Centre (NCSC) recently released its 2022 Annual Review, which reports on the state of cyber security threats in the country. As the UK’s technical authority for cyber security, the NCSC releases an annual report covering the cyber threats from the prior 12 months as well as analysis of potential […]
NHTSA Updates its Guidance on Cybersecurity Best Practices for the Safety of Modern Vehicles
On September 7, 2022 the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) released an updated edition of its Cybersecurity Best Practices for the Safety of Modern Vehicles, the last edition of which was published in 2016. This most recent edition of this non-binding guidance leverages agency research, industry voluntary standards, and […]
CISA Issues Request for Information Prior to Required CIRCIA Rulemaking
On September 12, 2022, the Cybersecurity and Infrastructure Security Agency (CISA) issued a request for information (RFI) seeking input from stakeholders on the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). Signed by President Biden in March, CIRCIA requires CISA to develop and implement regulations requiring covered entities to report information about covered […]