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Ted Dziekanowski thanks for posting. The NYDFS updates come at a time of heightened cyber regulation in the U.S and EU. Along side the EU DORA and Basel accords they add to the complexity of financial services cybersecurity risk management regulation for New York covered entities. But align regulatory requirements such as cybersecurity risk management governance and implementation with other regulations.
U.S and EU regulators are starting to increase oversight and assurance of cybersecurity risk management compliance and attestation. One assumes that these updates won’t add much additional costs to Class A firms, but will increase the pressure on boards by attesting compliance and increase board room legal and compliance risk. For CISOs and board members test cases in 2022 start to set precedence for cybersecurity incident management, the use of Whistleblowers and the FCA. Notably the Uber, Drizly, CHS and Aerojet rocketdyne cases. You can expect further clarity in 2022 as other cases come to trial.
One also expects the SEC cybersecurity risk management proposal to be released in early 2023, that will further increase the cyber regulatory burden for public firms. That includes some FIs licensed to in New York state.
#cybersecurity #cyberriskmanagement #cyberregulation #theaugustagroup #cyberlaw
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