On July 28, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) announced that they piloted an Artificial Intelligence (AI)-enabled vulnerability program to help detect and remediate vulnerabilities in the U.S. government’s critical networks, systems, and software, as required by Executive Order (EO) 14110. From late 2023 to early 2024, CISA performed the pilot program to […]
Cybersecurity
CISA and JCDC Conduct First-Ever Public-Private AI Security Incident Tabletop Exercise
On June 13, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) collaborated with the Joint Cyber Defense Collaborative (JCDC) to hold the federal government’s first tabletop exercise for “AI security incidents. JCDC led the exercise and, true to JCDC’s public-private partnership model, included over 50 participants from various government agencies and private-sector companies. For those […]
Pennsylvania Amends Data Breach Notification Law
Pennsylvania’s Governor recently approved amendments to the Commonwealth’s data breach notification law, which represent a significant overhaul to the law. As detailed below, the amended law makes a number of material changes, including adding a regulator notification requirement, lowering the threshold of impacted Pennsylvania residents triggering a notification requirement to the consumer reporting agencies, slightly […]
SEC Corporation Finance Provides Additional Guidance on the Disclosure of Material Cybersecurity Incidents in Form 8-K
On June 24, 2024, the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued five new Compliance and Disclosure Interpretations (“C&DIs”) related to the disclosure of “material” cybersecurity incidents in Item 1.05 of Form 8-Ks. The C&DIs present hypothetical fact patterns related to ransomware attacks and insurance reimbursement for damages […]
SEC Settlement Suggests the Agency’s Attempt to Regulate Cybersecurity Controls
On June 18, 2024, the SEC announced a $2.125 million settlement with R.R. Donnelley & Sons Co. (“RRD”) related to the company’s 2021 ransomware attack (the “Incident”). The settlement, and the SEC’s accompanying cease-and-desist order (the “Order”), portend the agency’s continued and increasing oversight over registrants’ cybersecurity policies and practices. Background RRD is a global […]