Banking and Finance Law Daily New York cautions regulated banking institutions on heightened cyber attack risks
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Monday, January 6, 2020

New York cautions regulated banking institutions on heightened cyber attack risks

By Charles A. Menke, J.D.

In an industry letter, the DFS warned of possible Iranian sponsored cyber attacks in retaliation against the United States for the death of Qassem Soleimani, and that regulated entities should be prepared to respond quickly to any suspected cyber incidents.

The New York Department of Financial Services (DFS) has issued an industry letter to all regulated entities stressing the need for heightened cybersecurity precautions in the wake of recent events involving Iran. Based on the "Iranian capabilities and history, U.S. entities should prepare for the possibility of cyber attacks" and "heighten their vigilance against cyber attacks," the DFS said.

The DFS recommended that regulated entities ensure that all vulnerabilities are patched and remediated, especially publicly disclosed vulnerabilities. Regulated entities should also ensure that employees are adequately prepared to deal with phishing attacks, fully implement multi-factor authentication, review and update disaster recovery plans, and respond quickly to further alerts from the government or other reliable sources.

The DFS stressed that regulated entities should promptly respond to any alerts or incidents even if outside of regular business hours, and to notify the DFS of any significant or noteworthy cyber attack. The DFS’s cyber regulation requires notification as promptly as possible, but no later than 72 hours after a material cybersecurity event. The DFS urged all regulated entities to notify DFS of any material incidents as soon as possible due to the increased risk, but no later than the required 72 hours, to allow the DFS to disseminate information about new cyber attacks as quickly as possible.

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