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
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…
UK Cyber Security and Resilience Bill – new obligations for the data centre sector
This blog post includes headline points on new obligations for the data centre sector proposed under the Cyber Security and Resilience Bill, and existing obligations under the NIS Regulations.
NIS Regulations Keeling Schedule for the Cyber Security and Resilience Bill – changes to the UK’s cyber security law
The Cyber Security and Resilience Bill proposes changes to the UK’s NIS Regulations. Without a ‘Keeling Schedule’ marking up the amendments, these can be difficult to track. We have prepared a mark-up reflecting the proposed changes.
Service provider outages test customer resiliency
On November 18, 2025, companies had another opportunity to test their resiliency when connectivity and security provider Cloudflare had an outage of about four hours, which resulted in several popular websites going offline while others managed to provide some services…
Update: CISA 2015 is reauthorized until January 2026
The Cybersecurity Information Sharing Act of 2015 (CISA 2015) has been temporarily reauthorized as part of the broader legislation passed on November 12, 2025, to reopen the federal government. Under the appropriation legislation, CISA 2015 is now reauthorized until January…
Happy Cyber Awareness Month
Happy October and Cyber Awareness Month! While October ends with ghosts and goblins and other scary monsters for Halloween, the entire month of October is dedicated to raising awareness of cyber security and preventing (and if necessary responding to) cyber…
CISA 2015 sunsets: Cyber Threat sharing without a net?
The Cybersecurity Information Sharing Act of 2015 (CISA 2015) expired on September 30, 2025, after Congress missed the reauthorization deadline. That lapse removes the decade-old legal framework that encouraged and protected cyber threat information sharing among companies, Information Sharing and…