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With the U.S Executive Office pushing ahead with cyber through the ONCD National Cyber strategy, the next phase of the program is critical. It’s delivery, delivery and delivery, and unfortunately U.S Federal Government has a poor track record in delivering cybersecurity. Money is not the problem, the U.S seems to have directed plenty of it towards cyber. The problem is ‘Will’ and demonstrating that the ONCD program can and will be delivered. FISMA and OMB A130 are 20 year old regulations that have been largely ignored by Federal Government, albeit FISMA 2023 is moving ahead through Congress.
Ted Dziekanowski will 2023 and onward be any different from the past 20 years? One suspect the introduction of DoJ oversight and regulatory cyber enforcement through the FCA, will make some difference. The SEC moving towards its own cybersecurity risk management regime affecting market entities; the EU regulating cyber through NIS 2, DORA and the CRA; Australia moving to regulate cyber, and the very real threat of cyber to national security. Point towards cybersecurity turned a compliance corner.
It will take real strong action from U.S Government and Federal Agencies to demonstrate to the international community that if you trade with the U.S, there are certain obligations that will have to be met. As the EU are also demonstrating. One suspects we have moved beyond the fud debate, but it will take a few demonstratable cases to set caselaw and build precedence.
One wonders if we are at a point where the only real alternative option to delivering cyber compliance, is to accept ransomware, financial crime and challenges to national security.
Stephen Pitt-Walker, JD, FGIA Rachel V. Rose, JD, MBA
#cybersecurity #cyberstrategy #cyberriskmanagement #cyberlaw #oncd
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