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NYDFS ties AI risk to cyber assessment obligation
The guidance doesn't impose new rules, but it tells examiners exactly where to look, and NYDFS has already found the gaps it's flagging.
NYDFS issued Sept. 10 guidance clarifying that annual cyber risk assessments under its 2017/2023 cybersecurity regulation must consider whether AI adoption, quantum computing advances, supply-chain attacks, ransomware evolution, and geopolitical conflict materially alter a firm's risk profile. The guidance does not create new obligations but identifies common gaps NYDFS has already observed during examinations, including failure to account for emerging technologies and concentration risk from third-party dependencies. Covered entities range from banks and insurers to their service providers.