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, […]
Privacy & Cyber Regulatory Enforcement
Arkansas Enacts Children and Teens’ Online Privacy Protection Act
On April 21, 2025, Arkansas Governor Sarah Huckabee Sanders signed into law the Arkansas Children and Teens’ Online Privacy Protection Act (Act), which will become effective on July 1, 2026. It draws inspiration from the federal Children and Teens’ Online Privacy Protection Act (COPPA 2.0) and provides stronger privacy protections for Arkansas residents under thirteen […]
Ninth Circuit Addresses Personal Jurisdiction Based on E-Commerce Data Collection in En Banc Decision
A recent decision by the Ninth Circuit Court of Appeals in Briskin v. Shopify, Inc., No. 22-15815, could impact the scope of personal jurisdiction over e-commerce and other entities that utilize cookies to collect personal information from visitors to the entities’ websites, particularly in California. Although the impact of the case remains to be seen, […]
FTC Publishes Amendments to COPPA Rule
On April 22, 2025, the Federal Trade Commission (FTC) published the finalized amendments (Amendments) to the Children’s Online Privacy Protection Rule (COPPA Rule) that would impose additional restrictions on website and online service operators that collect personal information from children under the age of thirteen. The Amendments will become effective on June 23, 2025. Operators […]
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 […]