How the SEC's Rules on Cybersecurity Incident Disclosure Are Exploited

This commentary discusses how the SEC’s new material cyber incident disclosure rules may be leveraged by ransomware actors such as ALPHV to intensify extortion pressures (e.g., citing MeridianLink), and urges public companies to prioritize proactive security, develop and rehearse incident response plans, and share learnings with the community to counter evolving double-extortion tactics and retain control of the narrative.