NYDFS Issues Its Report on the SolarWinds Cyber Attack

On April 27, 2021 NYDFS issued a report on the SolarWinds attack and regulated entities’ response. Per interactions with 100 regulated entities it found that:

• Some NYDFS licensees actually detected the attack before it became public but didn’t share

• No licensee reported that hackers actively exploited the network, consistent with other reporting that financial services companies were not actively targeted

• Licensees responded to the SolarWinds Attack swiftly; 94% of impacted companies removed the vulnerability introduced from their networks within 3 days by disconnecting and/or patching

• Some licensees’ patch management programs are immature and lack proper “patching cadence” needed to ensure timely remediation of high-risk cyber vulnerabilities

• Some licensed entities using its Orion product did not classify SolarWinds as a critical vendor, even though Orion had privileged access to the company’s network

• ENFORCEMENT TAKEAWAY: “This attack confirms the importance of vigorous third party risk management, which starts with a thorough assessment of an organization’s third party risk. . . [Cyber risk ] is an existential threat and we urge the industry to treat it as such.”


The report may be found here: https://www.dfs.ny.gov/system/files/documents/2021/04/solarwinds_report_2021.pdf


Matthew Levine joined Trish Sullivan of Deutschebank and Chris Boehing of Paul Weiss Rifkind Wharton & Garrison to discuss the new anti-money laundering amendments to the Bank Secrecy Act for theis episode of the International Institute of Banker’s podcast “Bank Talk.”   The podcast can be found here: