On January 14, 2025, the United Kingdom government published a consultation on ransomware proposing new measures to increase incident reporting and reduce ransom payments (the “Consultation”). The Consultation outlines three objectives in this regard and is open for responses until April 8, 2025. Proposal 1: Targeted Ban on Ransomware Payments The UK government is proposing […]
Security Breach
CISA and JCDC Conduct First-Ever Public-Private AI Security Incident Tabletop Exercise
On June 13, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) collaborated with the Joint Cyber Defense Collaborative (JCDC) to hold the federal government’s first tabletop exercise for “AI security incidents. JCDC led the exercise and, true to JCDC’s public-private partnership model, included over 50 participants from various government agencies and private-sector companies. For those […]
Data Breach Notification Requirements under the Safeguards Rule Now in Effect
For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial institutions were subject to breach-reporting obligations, these were set by non-GLBA legislation, such as state law, or by relatively narrow incident-reporting rules under Interagency Guidelines overseen by […]
CISA Posts Notice of Proposed Rulemaking Under CIRCIA
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) published a notice of proposed rulemaking (NPRM) implementing the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA). For additional background on CIRCIA, see our prior advisory. CISA is required to issue a final rule by October 4, 2025. Who is required to report covered […]
NY AG’s Office Announces Significant Cybersecurity Settlement with Healthcare Company
On January 5, 2024, the New York Attorney General’s Office (“NY AG”) announced a settlement with Refuah Health Center, Inc. (“Refuah”) based on the company’s alleged failures to appropriately safeguard its patients’ information, including failing to encrypt patient information or use multifactor authentication, which allegedly resulted in a May 2021 ransomware attack that impacted approximately […]