The New York Department of Financial Services (NYDFS) has released a new set of Frequently Asked Questions (FAQs 18–23) under 23 NYCRR Part 500, reinforcing its position that multifactor authentication (MFA) remains a critical component of a covered entity’s cybersecurity program. These FAQs provide highly prescriptive guidance, including clarifications on technical requirements for the “possession” […]
Privacy & Cyber Regulatory Enforcement
New EU Regulation Clarifies Cybersecurity Rules for IoT Devices and Other ‘Products with Digital Elements’
On November 28 2025, the European Commission adopted a regulation implementing the Cyber Resilience Act (‘CRA’) – an EU-wide law which lays down cybersecurity requirements for companies that design and sell ‘products with digital elements’. PDEs can take many forms including IoT devices, hardware components, and certain software. The CRA imposes cybersecurity obligations in connection […]
California AG Announces $1.4 Million Settlement with Mobile App Provider for Alleged CCPA Violations
On November 21, 2025, California Attorney General (AG) Rob Bonta announced a $1.4 million settlement with Jam City, Inc. (company), a mobile game app company, for alleged failures to enable in-app opt-outs from the sale and sharing of personal information across many of the company’s mobile apps as required by the California Consumer Privacy Act […]
SEC Dismisses Remaining Claims Against SolarWinds
On November 20, 2025, the Securities and Exchange Commission (SEC) dismissed its landmark enforcement action against SolarWinds Corp. and the company’s Chief Information Security Officer, Tim Brown. In 2023, the SEC’s enforcement action broke new ground as the first formal action by the Commission against a CISO and the first civil fraud action litigated by […]
NYDFS Issues Guidance on Managing Risks Related to Third-Party Service Providers
On October 21, 2025, the New York Department of Financial Services (“NYDFS”) published an Industry Letter (the “Letter”) outlining guidance on managing risks related to third-party service providers (“TPSPs”). NYDFS recognizes that as covered entities become more reliant on TPSPs, managing TPSPs “remains a crucial element of a Covered Entity’s cybersecurity program.” The Letter outlines […]