Cybersecurity Company in New York

Entity class is the first thing to settle, because Part 500 itself tiers the obligation. A defensible NYDFS Part 500 program for a small Class A or Class B covered entity (under USD 1B in assets, fewer than 2,000 employees) covers the risk assessment under 500.9, a written WISP, MFA rollout per amended 500.12, asset inventory per 500.13, third-party risk per 500.11 and 500.19, incident response per 500.16, BCDR per 500.16(e), and training per 500.14, followed by an annual run-rate for the risk-assessment refresh, annual penetration test, CISO certification preparation, quarterly tabletops, and vendor reassessments. Larger Class A entities (USD 20M+ in NY revenue, 2,000+ employees, USD 1B+ in assets) scale higher because of the independent audit, BSA-AML data feed integrations, and the bi-annual penetration test cadence under the November 2023 amendment. We give fixed-fee statements of work, not open T and M.

Part 500.17(a) requires a covered entity to notify the Superintendent of Financial Services within 72 hours of determining that a cybersecurity event has occurred, where the event would require notice to any government body, self-regulatory agency, or other supervisory body, or where the event has a reasonable likelihood of materially harming any material part of normal operations. The November 2023 amendments added ransomware payment disclosure within 24 hours and an extortion payment narrative within 30 days. We pre-stage the notification template, the determination workflow (who at the firm holds the formal determination authority), the legal review pipeline with outside counsel (Sullivan and Cromwell, Debevoise, Davis Polk cyber practices), and the parallel notification paths to FINRA, the SEC for Item 1.05 8-K assessment, the NY Attorney General under SHIELD, and OFAC if a sanctions nexus exists. The 72-hour clock does not start with a blank page when we have built the program correctly.

The SEC's cybersecurity disclosure rules adopted in July 2023 (Item 1.05 of Form 8-K and Regulation S-K Item 106) require a public-company registrant to disclose a material cybersecurity incident within 4 business days of materiality determination, plus annual governance and risk-management disclosure. The materiality determination itself is the hard part, and the SEC has signalled it will not accept indefinite delay. We build a materiality assessment workflow that runs in parallel with the NYDFS 72-hour determination, with pre-staged 8-K language, a cross-functional decision quorum (CISO, GC, CFO, audit committee chair), and a clear escalation path. The SolarWinds enforcement action (October 2023) and the resulting case law have reshaped what counts as material, and we keep the playbook current with each new SEC enforcement action and SDNY ruling.

The defensible NYC financial-services pattern in 2025 is CrowdStrike Falcon or SentinelOne Singularity for EDR and XDR (both have a heavy NYC bank install base), Splunk Enterprise Security or Microsoft Sentinel for SIEM (Splunk is the incumbent at most JPMorgan, Citi, Goldman, and Morgan Stanley vendor footprints; Sentinel is rising on the Azure-heavy mid-market), Wiz for CNAPP across AWS and Azure, Okta or Microsoft Entra ID for identity with FIDO2 phishing-resistant MFA per amended 500.12, Tenable or Qualys for vulnerability management, Snyk and Semgrep for application security, and Recorded Future plus Mandiant Advantage for threat intelligence. We size the stack to the firm: a 200-person broker-dealer does not need the same SIEM footprint as a regional bank, and we will say so before you sign the Splunk contract. The 24x7 SOC can be in-house, hybrid with a Manhattan or Jersey City NOC partner, or fully managed by a CrowdStrike Falcon Complete or Arctic Wolf tier.

We architect Zero Trust against CISA's Zero Trust Maturity Model v2 (identity, devices, networks, applications and workloads, data) and the NIST SP 800-207 reference architecture, sequenced by what actually reduces blast radius first in a financial-services environment. That usually means phishing-resistant FIDO2 MFA across all privileged identities, conditional access in Okta or Entra ID gated on device posture, microsegmentation in the data centre with Illumio or Akamai Guardicore, application-layer access through Cloudflare Access, Zscaler ZPA, or Netskope Private Access replacing the legacy VPN, and continuous verification through UEBA in the SIEM. The CrowdStrike Falcon identity threat protection module and the SentinelOne Ranger AD add real-time AD and Entra ID compromise detection. The NYDFS amended 500.12 effectively now demands phishing-resistant MFA for privileged accounts, which makes Zero Trust the path of least regulatory resistance.

Yes. PCI DSS 4.0 is fully in force as of 31 March 2024, with the future-dated requirements taking effect 31 March 2025 (including the new authenticated scanning, the targeted risk analysis for compensating controls, and the customised approach). For NYC merchants, processors, and any service provider in the cardholder data environment, we scope the build against the 4.0 control set, sequence remediation against the QSA assessment calendar (Coalfire, A-LIGN, Schellman, BDO are the QSAs we see most in NYC), and integrate the work with the parallel Part 500 program where the entity is also a covered NYDFS entity. Tokenisation, P2PE, and CDE network segmentation are designed in, not retrofitted, and the SAQ or ROC pathway is decided before architecture, not after.

Our incident response playbook is built for the actual sequence NYC firms face: detect, contain, eradicate, recover, notify, and litigate. Detection feeds from the SIEM and EDR through pre-tuned MITRE ATT&CK detections and Sigma rules. Containment runs through CrowdStrike Falcon or SentinelOne network containment with pre-approved isolation lists. Forensic preservation uses Velociraptor, KAPE, and EDR-native acquisition, with chain of custody documented for any litigation downstream. We coordinate with retained DFIR firms (Mandiant, CrowdStrike Services, Kroll Cyber, Stroz Friedberg, Unit 42) and outside counsel (Debevoise, Sullivan and Cromwell, Davis Polk cyber practices) on the formal investigation. Notification fans out in parallel: NYDFS 72-hour, SEC 4-day Item 1.05 if public, NY AG under SHIELD, HHS OCR if HIPAA, OFAC if a sanctions nexus exists, FINRA if a broker-dealer, and customer notice under state breach laws.

We default to AWS us-east-1 in Northern Virginia with us-east-2 in Ohio as a tested DR region for AWS-resident workloads, and Azure East US with East US 2 DR for Microsoft-heavy environments. Both are the regions NYDFS examiners and the Big Four auditors see most often, and both keep latency under 15 ms to the Equinix NY4 and NY5 colocation facilities that anchor a lot of NYC financial network architecture. PII, PHI, and cardholder data stay in US regions with KMS-managed encryption at rest, TLS 1.3 in transit, and customer-managed keys where regulatory posture requires it. SIEM and log retention is sized for the Part 500 minimum five-year retention on audit trails (500.6) and the longer retention some FINRA and SEC requirements add. SOC analyst access runs through Okta with FIDO2 MFA and session recording where the role requires it.