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NY DFS’s new MFA guidance: closing common gaps before the next exam

Photo of Ji Won Kim (US)Photo of Susan Ross (US)
By Ji Won Kim (US) & Susan Ross (US) on March 23, 2026

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

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By Nadège Martin (FR), Laura Helloco & Geoffroy Coulouvrat (FR) on March 19, 2026

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…

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Heightened Cyber Risks in the Middle East: Geopolitical Tensions Fuel Digital Conflict

Photo of Tim JonesPhoto of Shabnam KarimPhoto of Simon LambPhoto of Sajeedah Bari
By Tim Jones, Shabnam Karim, Simon Lamb & Sajeedah Bari on March 5, 2026

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

Photo of Ji Won Kim (US)Photo of Shushan Gabrielyan (US)Photo of Leslie Ozuna (US)
By Ji Won Kim (US), Shushan Gabrielyan (US) & Leslie Ozuna (US) on February 11, 2026

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

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By Marcus Evans (UK) & Rosie Nance on December 3, 2025

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. 

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NIS Regulations Keeling Schedule for the Cyber Security and Resilience Bill – changes to the UK’s cyber security law

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By Marcus Evans (UK) & Rosie Nance on December 3, 2025

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.

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Service provider outages test customer resiliency

Photo of Annmarie Giblin (US)Photo of Susan Ross (US)
By Annmarie Giblin (US) & Susan Ross (US) on November 26, 2025

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

Photo of Will Daugherty (US)Photo of Remi Gambino (US)
By Will Daugherty (US) & Remi Gambino (US) on November 13, 2025

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

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By Chris Cwalina (US) & Will Daugherty (US) on October 14, 2025

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?

Photo of Will Daugherty (US)Photo of Remi Gambino (US)
By Will Daugherty (US) & Remi Gambino (US) on October 2, 2025

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…

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