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NYDFS has gone through several updates recently. The enclosed is a great summary of the proposed second amendments released in November 2022, as applied to New York state covered FIs.
The updates increases the regulatory exposure of CISOs; the scope of corporate liability over affiliate organisations; the explicit requirement for cybersecurity audit, penetration testing and audits by 3rd parties; increased reporting requirements and explicit authority for the DFS to impose fines, penalties and sanctions on covered entities that have cyber events.
The challenges for many organisations will come with
1. Ensuring the CISO are suitably qualified and authorized.
2. Board members are properly trained.
3. Internal cyber, data governance and and information management policies are up to date.
4. Pen tests and 3rd party audits are in place and carried out.
5. Employee training is up to date and vendors agreements clearly documented.
6. Incident response and Disaster plans policies
Ted Dziekanowski
#cybersecurity #cyberriskmanagement #nydfs #cyberlaw #cyberregulation #theaugustagroup
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