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New Federal Law Mandates Cyber Incident and Ransomware Payment Reporting for Critical Infrastructure Industries

After years of lengthy debates, Congress passed and the President signed into law a bipartisan bill requiring entities in sectors deemed to constitute “critical infrastructure” to report certain cyber incidents and ransomware payments. Currently, companies may and often do voluntarily report cyber incidents to the FBI or other federal agencies,…

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SEC Proposes Expanded and Accelerated Cybersecurity Disclosure by Public Companies

As a significant step in its ongoing initiatives on the disclosure, management and oversight of cybersecurity risks and incidents, on March 9, 2022 the U.S. Securities and Exchange Commission (SEC) proposed new rules that would significantly increase cyber-related disclosures by public operating companies. The proposed rules would: Require disclosure in Form 10-Q…

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SEC Focus on Cybersecurity Begins To Take Shape

The U.S. Securities and Exchange Commission is implementing a campaign to overhaul the agency’s expectations around cybersecurity and cyber incident reporting for the financial services industry and corporate America generally. For example, in a recent speech, Chairman Gensler reiterated his focus on cybersecurity and underscored the SEC’s work to “improve…

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SEC Cybersecurity Rules Target Investment Advisers and Investment Companies

On February 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed a package of new rules and amendments to enhance cybersecurity preparedness and improve cyber resilience of investment advisers and investment companies against cybersecurity threats and attacks. If adopted, these rules will incorporate existing SEC staff guidance on cybersecurity policies and…

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