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New York’s Cyber Regulation Two Years Later: We’ve Only Just Begun

The Conclusion of the “Transitional Period” for New York’s Cybersecurity Regulation Marks the Beginning, Rather Than the End, of an Organization’s Compliance Efforts

Financial institutions will have to certify annually that their internal controls and cybersecurity practices remain up to snuff. And now that the transitional periods for implementing the cyber regulation have passed, covered institutions will need to certify that they have complied with each provision.


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Financial institutions regulated by New York’s Department of Financial Services (DFS) can breathe a sigh of relief, at least temporarily. Two years after DFS’s Cybersecurity Requirements for Financial Institutions took effect, and more than three years after the cybersecurity regulation was announced, the final provision of the law became effective on March 1 of this year.

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