NYDFS Cybersecurity Regulations Take Effect

New York’s new cybersecurity regulations (the “Regulations”) become effective on August 28, 2017, marking a significant milestone in what is likely to be a new era in cybersecurity regulation on both a national and international level.

As governments grapple with how best to address cyber threats to their citizens, businesses and national security, there is an increasing focus on the potential use of regulatory requirements to impose minimum cybersecurity standards, particularly in the financial services sector. As more states and nation states adopt cybersecurity requirements, financial institutions are facing increased compliance costs and potentially a diversion of resources away from risk mitigation to compliance with regulatory requirements. As the Regulations come into effect, we briefly take stock of their requirements, their impact on international best practices, and related global developments.