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CMMC 2.0 Update: DOD Proposed Rule Introduces Standard Terms for Contracts Subject to CMMC 2.0, Including Yet Another 72-Hour...

WHAT: The U.S. Department of Defense (DOD) just published the second of two proposed rules setting forth key requirements for its long-anticipated Cybersecurity Maturity Model Certification (CMMC) 2.0 program. The earlier...more

How Bad Is It Out There? Our Thoughts on Verizon’s 2024 Data Breach Investigations Report (DBIR)

Verizon released its Data Breach Investigations Report (DBIR) for 2024, an annual treat that highlights some trends companies should be aware of as they manage their cybersecurity programs and respond to and anticipate new...more

Cyber Update: SEC Issues New Guidance on Cybersecurity Incident Disclosure

On June 24, 2024, the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance (Corp Fin) added to its Compliance and Disclosure Interpretations (C&DI) related to disclosure of Material Cybersecurity...more

Calls for Cybersecurity Regulatory Harmonization Ramp Up in Congress, White House

The proliferation of cybersecurity regulations has the White House and Congress calling for harmonization to streamline regulations, focus on reciprocity, and decrease compliance costs. Senator Gary Peters (D-MI), chair of...more

CYBER UPDATE: White House Seeks Regulatory Harmonization While Exploring a Pilot for Reciprocity Amid Proliferation of Regulations

Companies, particularly those in “critical infrastructure” sectors, have seen a dramatic increase in cybersecurity regulatory requirements in just the past few years – and the White House is looking to move faster. At the...more

Darned if You Do, Darned if You Don’t: Recent Lessons from the SEC On Cyber Reporting

The Security and Exchange Commission (SEC) Director of the Division of Corporate Finance, Erik Gerding, released a statement on May 21, 2024 that may have regulated entities scratching their heads about compliance and the...more

New White House Policy Previews Increased Cybersecurity Oversight and Regulation

On April 30, 2024 the White House updated the foundational U.S. government policy that defines critical infrastructure (CI) sectors and establishes a coordination structure within the federal government to support owners and...more

DOJ Kicks Off Work to Regulate Foreign Access to Sensitive Personal Data Under New EO

On March 5, 2024, the Department of Justice (DOJ) issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern. The...more

NIST Cybersecurity Framework 2.0 Reveals Major Shifts in Federal Guidance

On February 26, 2024, the National Institute of Standards and Technology (NIST) released the Cybersecurity Framework version 2.0 (CSF 2.0). CSF 2.0 is a generational update to NIST’s foundational cybersecurity guidance, which...more

SEC Breach Reporting Rules Effective as of December 18

For most filers, the U.S. Securities and Exchange Commission’s (SEC) new Form 8-K rules for reporting material cybersecurity incidents took effect yesterday, December 18, 2023. The rule has been controversial and created some...more

Cyber Incident Reporting Guidance: DOJ Explains How It Will Determine if a Public Disclosure Poses Substantial National Security...

The cyber reporting landscape is rapidly shifting. Many agencies are developing rules, and a major player has been the U.S. Securities and Exchange Commission (SEC), with important questions arising about implementation of...more

SEC Cyber Reporting Mandates: How to Request a National Security or Public Safety Delay

On December 18, the Securities and Exchange Commission's (SEC) new disclosure requirements go into effect and will require public companies to publicly report material cybersecurity incidents within four days of making a...more

Ransomware Attacker Files SEC Complaint to Increase Pressure on Victim

The Black Cat/ALPHV ransomware group filed a complaint with the U.S. Securities and Exchange Commission (SEC) to allege that one of their victims failed to disclose a cyberattack to the SEC within four days, reports Bleeping...more

GAO Calls for Better Info-Sharing by ONCD and CISA After Cyberattacks; May be Inconsistent with New Mandates

Information sharing has seemed like the “holy grail” of federal cyber policy: sought after but elusive, especially to those who think it will solve their problems. At a time of increased regulation and looming mandates for...more

How to Fix the Cyber Incident Reporting Mess--DHS Weighs In [Audio]

Wiley’s cyber team talks about cyber incident reporting after a new report from DHS advising Congress on duplication of reporting regimes. With over 50 reporting requirements spread over 20 agencies, federal agencies and the...more

Biden Administration Looks at Harmonizing Cyber Regulations Amidst Flurry of New Activity

Cybersecurity continues to be top of mind for federal and state policymakers. This advisory identifies and analyzes some major recent developments that present opportunities and challenges in the coming months for a broad...more

SEC Adopts Controversial New Cybersecurity Disclosure Rules for Public Companies

Public companies will soon face new cybersecurity disclosure requirements from the Securities and Exchange Commission (SEC), which voted last week to approve a controversial new cybersecurity rule. The final rule—which is...more

National Cybersecurity Strategy Outlines A New Era of Cybersecurity Regulation

On March 2, 2023, the White House Office of the National Cyber Director (ONCD) released the National Cybersecurity Strategy (“Strategy”). The Strategy outlines the Administration’s priorities for cyber regulations and policy....more

White House Pivots on Cyber: Voluntary Compliance Carrots Are Being Replaced By Big Regulatory Sticks

The White House released the long-anticipated National Cybersecurity Strategy on March 2, 2023 setting out five (5) pillars articulating key themes and Administration priorities. Coming more than two years into the Biden...more

DHS CISA Kicks off Work to Regulate Critical Infrastructure Incident Reporting

Congress has directed the U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) to create broad new rules for mandatory cyber incident reporting to be imposed on critical...more

[Podcast] NSA Cybersecurity Services for Defense Contractors [Audio]

Lyn Brown sits down with Kristina Walter, Chief of the Defense Industrial Base Cybersecurity within the National Security Agency’s Cybersecurity Collaboration Center, and Ben Kastan who is the Associate General Counsel for...more

Rethinking the Cybersecurity Challenge from an Intelligence Community Perspective

Director of National Intelligence (DNI) Avril Haines was interviewed by Michele Flournoy, Co-Founder and Managing Partner at WestExec Advisors and former Under Secretary of Defense for Policy, on the first day of the RSA...more

Multi-Faceted Extortion: Insider Look at Ransom Payments and Cyber Defense

Day 3 at RSA Conference 2022 was filled with fascinating discussions on enhancing our cyber defenses to defeat the ever-proliferating spate of increasingly common and expensive ransomware attacks....more

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