Cybersecurity Law Report | Two Settlements Show NYDFS’ Hidden Power to Use Other States’ Breach Laws

Today, on May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take effect.  Although the Second Amendment was originally adopted in November of 2023, NYDFS established a multi-year rollout of the Second Amendment’s requirements, […]

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Eight years ago, on March 1, 2017, the New York Department of Financial Services enacted its landmark cybersecurity regulation covering financial services companies, 23 NYCRR Part 500, known as “Part 500.”  Part 500 was the first state regulation to enumerate, in great detail, the elements of a cybersecurity program that a covered financial service company […]

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Our Privacy, Cyber & Data Strategy Team explores new guidance from the New York Department of Financial Services for covered entities to combat what it considers the most pressing cybersecurity risks of artificial intelligence (AI).