As cyber incidents become more costly and complex, organisations are facing increasing exposure to personal data claims, mass actions and contractual disputes. We explore the key litigation trends, emerging risks and practical considerations shaping the UK data breach claims landscape.
Cybersecurity
NYDFS levies $250,000 fine on licensee for inadequate cyber risk assessment
On August 5, 2026, the New York Department of Financial Services (NYDFS) entered into a consent order with Order Express, Inc., a money transmitter licensed by NYDFS. Although Order Express qualified for a limited exemption under the NYDFS cybersecurity regulation…
AI Appreciation Day 2026 and key developments in governance and compliance
As artificial intelligence (AI) becomes embedded in business operations, data protection frameworks are increasingly shaping how organizations manage AI use. This update highlights key regulatory developments, including risk-based approaches and sector-specific rules, and outlines practical considerations for compliance…
NYDFS issues guidance “in a heightened cybersecurity environment”
On May 21, 2026, the New York Department of Financial Services (NYDFS) issued industry guidance to licensees regarding security measures they should consider taking “in a heightened cybersecurity threat environment.” Even organizations not subject to NYDFS regulation may want to …
When AI becomes the cyber attacker: Mythos and what comes next
Anthropic’s April 7, 2026 announcement that it built a model too powerful for public consumption, Claude Mythos Preview (Mythos), marks a notable moment for the legal, compliance, and cybersecurity communities. It is no surprise that the US Department of the…
NYDFS Cybersecurity Enforcement: US$2.25m Fine Against Delta Dental

On April 30, 2026, the New York Department of Financial Services (NYDFS) announced a consent order with Delta Dental Insurance Company and Delta Dental of New York, Inc. for alleged violations of the NYDFS Cybersecurity Regulation relating to the 2023…
NY DFS’s new MFA guidance: closing common gaps before the next exam

Multi‑factor authentication (MFA) is now a well-established baseline cybersecurity control. The amended New York Department of Financial Services (NY DFS) solidified that understanding and expanded MFA requirements under 23 NYCRR Part 500 (the NY DFS…
Cybersecurity and Personal Data: The CNIL toughens its stance


On 9 February 2026, the Commission Nationale de l’Informatique et des Libertés (CNIL) published its 2025 report on its enforcement action. Beyond the €487 million – in cumulative fines – largely driven (unsurprisingly) by two sanctions related to cookies, another…
Heightened Cyber Risks in the Middle East: Geopolitical Tensions Fuel Digital Conflict



Introduction
The latest developments in the Middle East – marked by a significant surge in military activity and retaliatory strikes across the region – have been accompanied by a parallel intensification of cyber operations.
It is common in such situations…
The DOJ’s civil cyber-fraud initiative lives on: Insights from cybersecurity enforcement through the False Claims Act
The False Claims Act (“FCA”), the U.S. federal government’s principal civil anti-fraud statute, imposes liability on entities that knowingly submit, or cause the submission of, false or misleading claims for payment to the United States. The FCA has long served…











