With near-daily reports of foreign hacking, exposure of personal information, and corporate data breaches, cybersecurity sits at the forefront in the minds of many, including the federal government and global regulators. This September, the White House announced a new National Cyber Strategy, outlining how the United States intends to respond to vulnerabilities created by a globally-connected cyberspace where individuals, organizations, and nations interact, advance their interests, and hold sensitive data. National Cyber Strategy of the United States of America, September 2018. The strategy committed “to identify[ing] gaps and potential mechanisms for bringing foreign based cyber criminals to justice” and raised the importance of collaborating with international law enforcement given the “borderless nature of cybercrime.” Id. at 11.

Concurrently with this strategy, recent actions by regulators in the U.S. and abroad have made clear that they expect companies to pull their weight by taking adequate cybersecurity measures. Also in September, the Department of Justice’s Cybersecurity Unit issued revised guidance on how organizations should anticipate and respond to cybersecurity incidents. Best Practices for Victim Response and Reporting of Cyber Incidents, September 2018. Recent enforcement actions from U.S. and U.K. regulators highlight the risks companies face if their cybersecurity measures are deemed inadequate.

Voya Financial Advisors

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