NYDFS Issues Frontier AI Advisory and Guidance for Heightened Cyber Threat Environment

On May 21, 2026, the New York Department of Financial Services (“NYDFS”) issued two Industry Letters to the organizations it regulates (“Regulated Entities”): “Heightened Cybersecurity Risks Associated with Frontier AI Models” (the “Advisory”) and “Guidance on Measures Regulated Entities Should Consider in a Heightened Cybersecurity Threat Environment” (the “Guidance”) (collectively, the “Letters”). The Letters discuss various recommended security controls Regulated Entities should consider in…
By: Alston & Bird