What sorts of incident response changes are you implementing to satisfy regulatory requirements for incident reporting? How can organizations ensure their processes support compliance needs and create an audit trail that demonstrates that?

Before making decisions like paying a ransom, consult with your board and review your cyber liability insurance to avoid invalidating policies. It's important to have a comprehensive view of all key vendors, players, and insurance requirements. You also have to make sure that your incident response plan covers the entire scope of your organization's needs, not just specific areas. Collaboration with enterprise risk management and other relevant departments is crucial to cover all your bases from start to finish.

Regular tabletop exercises and simulations are essential to ensure your incident response plan is compliant as well as effective. In the financial sector, where regulations are stringent, it's crucial to align your IR plan with compliance and legal obligations. New regulations, like the Cyber Incident Reporting for Critical Infrastructure Act, require timely reporting. Consistency in reporting across regulators is key because discrepancies can lead to scrutiny. You can also lean on third-party support from agencies like the FBI for additional assistance.

It's important to have breach coaches and legal support, both internally and externally, to navigate the complexities of regulatory reporting. These experts can guide you through the chaos that often accompanies incident reporting. A well-prepared communication plan is also vital to address both regulatory bodies and potentially the media. And of course, practice these scenarios through crisis management exercises to maintain readiness.

Regulatory compliance in incident response is crucial, especially with prescriptive obligations like the Defense Federal Acquisition Regulation Supplement (DFARS) for safeguarding controlled unclassified information. We focus on automation to streamline our reporting processes, using tools like generative AI to give us accurate and consistent data reporting. This helps avoid underreporting or other errors that can lead to liability. The Cybersecurity Maturity Model Certification (CMMC) adds another layer of reporting, especially concerning supply chain accountability, so it's essential to tag and persist data correctly to understand the impact of any data loss and support accurate reporting.