On August 1, 2022, Robinhood Crypto LLC (“RHC”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) based on “serious deficiencies” related to anti-money laundering (“AML”), cybersecurity, and virtual currency that were identified in DFS’s examination of RHC covering the period from January to September 2019.[1] RHC is
Cybersecurity + Data Privacy
A New York State of Mind? New Cybersecurity, Privacy, and Data Protection CLE Requirements in New York

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NYDFS Announces Draft Amendments to Cybersecurity Regulation
On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Cyber Security Regulations. The Amendments, if adopted, would further regulatory trends and impose important new requirements on covered entities.
The Amendments contain three significant changes relating to ransomware. First, the Amendment specifically adds “the deployment of ransomware…
Cybersecurity Mesh Defeats a Siege Mentality

Today’s growing cybersecurity threat environment has many firms feeling besieged, but an effective modern response is available that protects hybrid cloud and remote work scenarios with an adaptable mesh rather than an impregnable wall.
A siege mentality has long pervaded attempts to secure IT networks, encrypt data, and control access to a law…
New SixFifty Product Automates Compliance with All State Data Privacy Laws

SixFifty, the technology subsidiary of the law firm Wilson Sonsini Goodrich & Rosati, is today launching a tool to help companies comply with the patchwork of data privacy laws in the United States by automating the creation of customized compliance documents.
Five U.S. states — California, Colorado, Virginia, Utah, and Connecticut — have…