The upshot, for busy people:

  • Realizing value and managing risk in investments and acquisitions of digital assets businesses means understanding several key areas of the target’s business—among them, cybersecurity, data privacy and regulatory positions.
  • This is particularly challenging in light of the pace of innovation in these technologies and the intersecting, evolving regulations that apply

On October 22, 2021, the New York Department of Financial Services (“NYDFS”) issued an interpretive letter that provides guidance on how entities regulated by NYDFS (“Covered Entities”) may comply with the NYDFS Cybersecurity Regulation by adopting the cybersecurity program of an affiliate (“Affiliate Program Letter”).1 According to the Affiliate Program Letter, a Covered Entity

As the decade comes to a close, new technologies are having a major impact on how insurance industry participants conduct their operations – especially how they collect, process, analyze, store and disseminate vast amounts of data – as well as how they interact with those with whom they do business. In recent years, blockchain technology