As an update to prior coverage of the FTC’s final revisions to the Gramm-Leach-Bliley Safeguards Rule (Final Rule), following its publication in the Federal Register on December 9, 2021, the Final Rule now will take effect on January 8, 2022, 30 days after publication in the Federal Register. Revisions to the Final Rule include an […]
Privacy & Cyber Regulatory Enforcement
NYDFS Issues Guidance on Multi-Factor Authentication
The New York Department of Financial Services (NYDFS) continues to refine its position regarding the importance of and requirements regarding Multi-Factor Authentication (MFA), as evidenced most recently with the release of new guidance. This new guidance is consistent with its June guidance, in which NYDFS clarified its expectation that NYDFS-regulated covered entities subject to 500.12 […]
China’s Initial Draft Regulations on the Management of Online Data Security: Important Takeaways
On November 14, 2021, the Cyberspace Administration of China (CAC) released draft Regulations on the Management of Online Data Security (the “Regulations”) for China’s data privacy and security laws, including the Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL). Consistent with such laws, the Regulations broadly apply to processing […]
Federal Bank Regulatory Agencies Release Final Rule to Require Notification of Cyber Incidents
On November 18, 2021, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation jointly announced the approval of a final rule to improve the sharing of information about cyber incidents that may affect the U.S. banking system. The rule applies to […]
Department of Defense Suspends the CMMC Pilot Program And CMMC Requirements In DoD Solicitations Pending Major Changes For CMMC 2.0.
The Department of Defense (“DoD”) recently announced it will be revamping the nascent Cybersecurity Maturity Model Certification (“CMMC”) program pending two separate rulemaking processes. As detailed below, the DoD will be updating “the program structure and the requirements to streamline and improve implementation of the CMMC program.” We will be monitoring the rulemaking process for […]