How Is COVID-19 Affecting Cybersecurity Risk, Readiness, Reporting and NYDFS Enforcement?

The New York Department of Financial Services’ new guidance on cybersecurity during the COVID-19 pandemic targets cybersecurity risks that arise from remote working and increased phishing. We examine the April 13, 2020, guidance with context from remarks made by an NYDFS cybersecurity official at the Cybersecurity Docket’s Incident Response Forum, as well as from our conversation with a former NYDFS head of compliance, about how companies can comply during the crisis, and whether regulators’ priorities have changed. See “The Hidden Requirements in NYDFS’ Cybersecurity Regulation” (Oct. 24, 2018).

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