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Data Security Compliance with the NYDFS Cybersecurity 
Requirements for Financial Services

How Thales helps organizations comply with the NYDFS

New York State Department of Financial Services Cybersecurity Requirements

Regulation | Active Now

The New York State Department of Financial Services (NYDFS) Cybersecurity Requirements, or 23 NYCRR Part 500 regulation, requires that regulated institutions implement, maintain, and annually certify that they have cybersecurity programs in place to protect the integrity of their information systems and customers’ data.

The regulation promotes the protection of customer information as well as the information technology systems of regulated entities. This regulation requires each company to assess its specific risk profile and design a program that addresses its risks in a robust fashion. Senior management must take this issue seriously, be responsible for the organization’s cybersecurity program, and file an annual certification confirming compliance with these regulations. HIPAA Rules and Regulations lay out three types of security safeguards required for compliance:

Which companies are supervised by the NYDFS?

Any institution that needs a license, registration, or charter from the New York State Department of Financial Services is regulated by the NYDFS. Examples of covered entities include state-chartered banks, foreign banks licensed to operate in the state of New York, licensed lenders, private bankers, savings and loans associations, mortgage companies, insurance companies, and other financial service providers.

When did the NYDFS Cybersecurity Requirements go into effect?

The initial phase of the New York State Cybersecurity Requirements for Financial Services Companies took effect on March 1, 2017. However, the entirety of the requirements was only enforced two years later, by March 1, 2019.

What are the penalties for NYDFS Cybersecurity Requirements non-compliance?

Under NY Banking Law, the NYDFS penalties start at $2,500 a day for each day of noncompliance with NYDFS Part 500. If noncompliance is determined to be a “pattern” by the NYDFS superintendent, the fine may increase to $15,000 a day. If the superintendent decides that any violations have been committed “knowingly and willfully,” the fine will jump to $75,000 daily.

Recent 2022 enforcement actions imposed monetary penalties in the $4.5 million to $5million range.

How can Thales help with NYDFS Cybersecurity Requirements compliance?

Thales helps organizations comply with the NYDFS Cybersecurity Requirements by assessing risk, managing access, and protecting data at rest and in-motion.

NYCRR Part 500: Cybersecurity Requirements for Financial Services Companies

This regulation requires each company to assess its specific risk profile and design, implement, maintain, and annually certify a cybersecurity program that addresses its risks and protects customer information as well as information technology systems.

Thales helps organizations by:

  • Providing a complete audit trail
  • Managing and monitoring access privileges
  • Securing development of applications
  • Assessing risk
  • Managing third party service provider risk
  • Providing multi-factor authentication
  • Encrypting non-public information

NYDFS Part 500 Requirement:


“…include audit trails designed to detect and respond to cybersecurity events.”


“…monitor and log the activity of authorized users and detect unauthorized access.”

Thales Solutions:

Thales Data Security Solutions maintain extensive access logs and prevent unauthorized access. In particular, CipherTrust Transparent Encryption security intelligence logs and reports streamline compliance reporting and speed up threat detection using leading security information and external SIEM systems.

SafeNet Trusted Access allows organizations to respond to and mitigate the risk of data breach by providing an immediate, up to date audit trail of all access events to all systems. Automated reports document all aspects of access enforcement and authentication. In addition, the service automatically streams logs to external SIEM systems.


“…limit user access privileges to Information Systems.”

Thales OneWelcome identity & access management solutions limit the access of internal and external users based on their roles and context. Backed by strong authentication (MFA), granular access policies and fine-grained authorization policies help ensuring that the right user is granted access to the right resource at the right time; whereby minimizing the risk of unauthorized access.

CipherTrust Transparent Encryption encrypts sensitive data and enforces granular privileged-user-access management policies that can be applied by user, process, file type, time of day, and other parameters. It provides complete separation of roles where only authorized users and processes can view unencrypted data


“...ensure the use of secure development practices for in-house developed applications utilized by the Covered Entity...”

CipherTrust Platform Community Edition makes it easy for DevSecOps to deploy data protection controls in hybrid and multi-cloud applications. The solution includes licenses for CipherTrust Manager Community Edition, Data Protection Gateway, and CipherTrust Transparent Encryption for Kubernetes.

CipherTrust Secrets Management is a state-of-the-art secrets management solution, which protects and automates access to secrets across DevOps tools and cloud workloads including secrets, credentials, certificates, API keys, and tokens.

Thales Data Protection on Demand (DPoD) is a cloud-based marketplace that offers Luna hardware security modules HSMs and CipherTrust solutions as a service. This enables in-house teams to leverage these proven and certified data security solutions easily and securely in their own offerings.


“…conduct a periodic Risk Assessment of the Covered Entity’s Information Systems.”

CipherTrust Data Discovery and Classification identifies structured and unstructured sensitive data on-premises and in the cloud. Built-in templates enable rapid identification of regulated data, highlight security risks, and help uncover compliance gaps.


“...ensure the security of Information Systems and Nonpublic Information that are accessible to, or held by, Third Party Service Providers.”

CipherTrust Cloud Key Manager can reduce third party risks by maintaining on-premises under the full control of the financial institution the keys that protect sensitive data hosted by third party cloud providers under “bring your own keys” (BYOK) systems.

CipherTrust Transparent Encryption provides complete separation of administrative roles where only authorized users and processes can view unencrypted data. Unless a valid reason to access the data is provided, sensitive data stored in a third-party cloud will not be accessible in cleartext to unauthorized users.

Thales Data Security solutions offer the most comprehensive range of data protection, such as Thales Data Protection on Demand (DPoD) that provides built in high availability and backup to its cloud-based Luna Cloud HSM and CipherTrust Key Management services.


“…shall use effective controls, which may include Multi-Factor Authentication.”

SafeNet Trusted Access is a cloud-based access management solution that provides commercial, off-the-shelf multi-factor authentication with the broadest range of hardware and software authentication methods and form factors for cybersecurity protection.


“…Implement controls, including encryption, to protect Nonpublic Information held or transmitted by the Covered Entity both in transit over external networks and at rest.”

Protect Data at Rest:

CipherTrust Data Security Platform provides multiple capabilities for protecting data at rest in files, volumes, and databases. Among them:

  • CipherTrust Transparent Encryption delivers data-at-rest encryption with centralized key management and privileged user access control. This protects data wherever it resides, on-premises, across multiple clouds, and within big data and container environments.
  • CipherTrust Tokenization permits the pseudonymization of sensitive information in databases while maintaining the ability to analyze aggregate information.
  • CipherTrust Enterprise Key Management streamlines and strengthens key management in cloud and enterprise environments over a diverse set of use cases.

Protect keys and certificates:
Luna Hardware Security Modules (HSMs) protect cryptographic keys and provide a FIPS 140-2 Level 3 hardened, tamper-resistant environment for secure cryptographic processing, key generation and protection, encryption, and more. Luna HSMs are available on-premises, in the cloud as-a-service, and across hybrid environments.

Protect data in motion:
Thales High Speed Encryptors (HSE) provide network-independent, data in-motion encryption (layers 2, 3, and 4) ensuring data is secure as it moves from site-to-site or from on-premises to the cloud and back. Our network encryption solutions allow customers to better protect data, video, voice, and metadata from eavesdropping, surveillance, and overt and covert interception— without performance compromise.

Related Resources

Data Security Compliance With the NYDFS Cybersecurity Requirements for Financial Services - Compliance Brief

Data Security Compliance With the NYDFS Cybersecurity Requirements for Financial Services - Compliance Brief

How Thales security solutions can help with The New York State Department of Financial Services (NYDFS) Cybersecurity Requirements for Financial Services Companies.

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