Insights · Looking Back

Looking Back: 2024

Every week of 2024, one article each.

53 articles

January 2024

  1. Week of 1 January 2024

    For FinCEN’s beneficial ownership launch, the hardest design problem was shrinking

    FinCEN opened beneficial ownership filing on January 1, 2024 to tens of millions of small companies while the law faced constitutional challenge. A public obligation at that scale has four design problems, and the last, how it narrows, is rarely planned.

    • Government
    • Customer & Citizen Experience
    • 5 min read
  2. Week of 8 January 2024

    Why the SEC’s hijacked account was most valuable the day before a decision

    The false bitcoin ETF post from the SEC’s X account came one day before the actual approval, when markets were primed to believe it. Agencies whose announcements move markets or behavior should secure official accounts as privileged credentials, by the calendar, and for the audience.

    • Government
    • Security & Resilience
    • 5 min read
  3. Week of 15 January 2024

    Major incident, by formula: DORA’s first standards moved the call from judgment to data

    DORA’s January 2024 standards defined a major ICT incident as a calculation over clients, transactions, downtime, data and cost. Banks that left those inputs outside their incident tooling could not classify on time, however good their playbooks.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  4. Week of 22 January 2024

    Test tenants are production when their apps can reach production

    Midnight Blizzard reached Microsoft’s executive mailboxes through a test tenant account and an old OAuth app. Whether any non-production identity is a production risk turns on three properties: who can log in to it, what it can reach, and who would notice it acting.

    • Cross-sector
    • Platforms & Architecture
    • 5 min read
  5. Week of 29 January 2024

    Why CISA’s Ivanti disconnect order was decided by people, before it was issued

    CISA gave federal agencies about two days to unplug and rebuild their Ivanti gateways. The steps were documented. What decided who met the deadline was who could authorize cutting remote access, who could rebuild the devices, and where agencies sat in their contractors’ queues.

    • Government
    • Operations & Workforce
    • 5 min read

February 2024

  1. Week of 5 February 2024

    Part 2’s single consent freed the recipients and bound the source

    HHS’s 2024 Part 2 rule let hospitals and payers that receive substance use disorder records treat them almost like other health data. The treatment programs that create them, and the legal teams that answer subpoenas, carried more obligation than before.

    • Healthcare
    • Regulation & Compliance
    • 5 min read
  2. Week of 12 February 2024

    Convincing faces, unauthenticated seats: the Hong Kong deepfake was a meeting-identity failure

    The deepfaked video call that moved about US$25 million beat a meeting, not a payment system. Most firms let staff treat a face on screen as identity. Banks need controls at the invitation, inside the meeting, and at the handoff to money.

    • Financial Services
    • Security & Resilience
    • 5 min read
  3. Week of 19 February 2024

    How Change Healthcare’s customers decided whether to pull the plug, and when to plug back in

    When ransomware hit the largest US claims clearinghouse, every connected provider faced the same call. Cutting the connection was quick. Knowing what to cut, and what proof to demand before reconnecting, depended on preparation few had done.

    • Healthcare
    • Security & Resilience
    • 5 min read
  4. Week of 26 February 2024

    CSF 2.0’s biggest addition was the one a security team could not deliver

    NIST’s new Govern function looked like a security framework update. Its six categories assign work to executives, HR, procurement and boards. Organizations that treated it as a mapping exercise for the CISO missed what had changed.

    • Cross-sector
    • Operations & Workforce
    • 5 min read

March 2024

  1. Week of 4 March 2024

    Days of cash on hand was the resilience metric that mattered in the Change Healthcare outage

    Two weeks into the Change Healthcare outage, the federal response was about money. For providers that were never attacked, survival turned on three financial questions: how long they could last, who would lend to them, and who would finally bear the loss.

    • Healthcare
    • Economics & Procurement
    • 5 min read
  2. Week of 11 March 2024

    Why the AI Act left bank credit models with the supervisor they already had

    The AI Act text adopted in March 2024 routed high-risk credit scoring through banking supervision and let existing governance satisfy some duties. For banks, the work was separating what model risk management already met from what it never covered.

    • Financial Services
    • Data & AI
    • 5 min read
  3. Week of 18 March 2024

    The governors’ water letter handed one problem to three state secretaries

    The March 2024 White House and EPA letter invited each state’s environmental, health and homeland security secretaries. That list was the finding: water cybersecurity in a state sits with a regulator, a funder and a responder, and few governors had named anyone to join them.

    • Government
    • Security & Resilience
    • 5 min read
  4. Week of 25 March 2024

    Easy to grant, hard to defend: M-24-10 put every federal AI exception on the record

    The final OMB memo kept the draft’s comply-or-stop deadline and added something sharper. Every way out of it, whether a determination, a waiver or an extension, now needed a named signer, documented evidence and a public or OMB-reviewed record.

    • Government
    • Data & AI
    • 5 min read

April 2024

  1. Week of 1 April 2024

    Agencies buy a cloud provider’s security culture whether or not the contract mentions it

    The Cyber Safety Review Board blamed the 2023 Exchange Online intrusion on Microsoft’s security culture. Agencies cannot audit a culture, but the report showed three places it leaves evidence a buyer can demand: secrets, disclosure and defaults.

    • Government
    • Economics & Procurement
    • 5 min read
  2. Week of 8 April 2024

    How the APRA draft moved privacy compliance to the customer’s side of the counter

    The American Privacy Rights Act draft never passed. Its distinctive features let individuals act directly, through requests, machine-readable opt-out signals and lawsuits. Those three channels, already arriving through state law, are where regulated organizations’ privacy programs are now judged.

    • Cross-sector
    • Customer & Citizen Experience
    • 5 min read
  3. Week of 15 April 2024

    Revised advisories: in April 2024, the vendor’s first word on an edge device was rarely its last

    Palo Alto withdrew a mitigation within four days, and MITRE disclosed a breach through Ivanti gateways it had worked to secure. Agencies that could check exposure, integrity and recovery for themselves did not have to wait for the vendor’s next revision.

    • Government
    • Platforms & Architecture
    • 5 min read
  4. Week of 22 April 2024

    HIPAA’s reproductive health attestation put the burden of purpose on the requester

    HHS’s April 2024 rule made police, courts and oversight bodies sign a statement of purpose. That shifted paperwork onto requesters but left hospitals with judgments no form could make, under a rule a court vacated in 2025.

    • Healthcare
    • Regulation & Compliance
    • 5 min read
  5. Week of 29 April 2024

    Why Change Healthcare’s missing MFA was a deal-integration failure

    UnitedHealth’s testimony traced the Change Healthcare attack to a remote-access portal without MFA, about sixteen months after the acquisition closed. Health care buyers should treat inherited internet-facing access as a closing condition, an interim-period control set and a board-level exception list.

    • Healthcare
    • Security & Resilience
    • 5 min read

May 2024

  1. Week of 6 May 2024

    Bigger network, thinner safety net: Ascension’s outage hit every sister hospital at once

    A large system’s hospitals normally cover for each other with beds, staff and shared services. When ransomware took Ascension’s shared platforms down across its markets, that internal mutual aid failed together, and the help had to come from outside.

    • Healthcare
    • Operations & Workforce
    • 5 min read
  2. Week of 13 May 2024

    The vendor clock: amended Regulation S-P rests on a 72-hour promise someone else makes

    The SEC’s 2024 Regulation S-P amendments gave customers a 30-day breach notice and required service providers to report within 72 hours. For broker-dealers and advisers whose customer data sits mostly with vendors, that second clock decides how well the first one works.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  3. Week of 20 May 2024

    How Windows Recall put a possible public record where no records officer could reach it

    Recall’s redesign answered the security objections by keeping screen snapshots local, sealed to the user and self-expiring. Those same three properties put the snapshots outside the search, hold and retention tools agencies use to meet public records and discovery duties.

    • Government
    • Data & AI
    • 5 min read
  4. Week of 27 May 2024

    Snowflake’s stolen logins put the contractor’s laptop inside the bank’s perimeter

    The 2024 campaign against Snowflake customers broke no platform. It used passwords stolen from infected machines, often contractors’, and walked out with bulk data. Each stage, from theft to login to extraction, was a control point the customer owned.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

June 2024

  1. Week of 3 June 2024

    Synnovis put a price on pathology consolidation that no contract carried

    The ransomware attack on Synnovis showed that consolidating a region’s pathology into one partner saves money every year and concentrates a rare, very large loss. The business case counted the savings. Nobody’s contract, budget or insurance carried the loss.

    • Healthcare
    • Economics & Procurement
    • 5 min read
  2. Week of 10 June 2024

    Why banking-as-a-service margins never covered the cost of knowing whose money it was

    The Fed’s order against Evolve showed that sponsor-bank revenue grew with balances while the costs of reconciliation, oversight and partner failure grew with the number of programs. Banks that priced only the first side carried the second.

    • Financial Services
    • Economics & Procurement
    • 5 min read
  3. Week of 17 June 2024

    Old ban, new deadline: Kaspersky’s exit reached the governments Washington’s 2017 order never covered

    Federal agencies had dropped Kaspersky years earlier. The June 2024 Commerce determination reached counties, school districts, utilities and contractors with a fixed date, and showed that replacing a security product is a procurement project with three costs most public budgets had never estimated.

    • Government
    • Economics & Procurement
    • 5 min read
  4. Week of 24 June 2024

    How polyfill.io slipped past hospital tag reviews that checked each script only once

    Hospital script reviews were built after 2022 to stop patient data leaving through tracking tags. Polyfill.io showed the opposite risk: approved code that changed after approval and sent patients elsewhere. Managing it takes checks on the source, the content and the response.

    • Healthcare
    • Customer & Citizen Experience
    • 5 min read

July 2024

  1. Week of 1 July 2024

    Records over deference: after Loper Bright, an agency’s best defense sat in its files

    Four Supreme Court decisions in five days ended deference on statutory meaning, kept old rules open to new challengers, faulted an agency’s explanation and moved penalty cases to juries. What agencies could still defend lived in their records, which most managed badly.

    • Government
    • Regulation & Compliance
    • 5 min read
  2. Week of 8 July 2024

    A credit union’s promises in an outage are set by its architecture, years before the attack

    Patelco’s members met its ransomware attack as four questions: can I use my money, what happened to my data, how do I get back in, who pays. Each answer was largely fixed by design and policy choices made long before June 2024.

    • Financial Services
    • Customer & Citizen Experience
    • 6 min read
  3. Week of 15 July 2024

    Channel File 291 measured every recovery plan in hands per device

    The faulty CrowdStrike update turned remotely managed Windows estates into a field-service job. Recovery speed came down to three constraints most plans never modeled: access to recovery secrets, people at keyboards, and the order of repair.

    • Cross-sector
    • Operations & Workforce
    • 5 min read
  4. Week of 22 July 2024

    Why North Korea’s fake remote hires succeed in the gaps between HR, IT and security

    KnowBe4’s account of hiring a North Korean IT worker showed a scheme built to pass four hand-offs, each owned by a different team. Controls work when one identity is carried from interview to offer, onboarding, device and daily work.

    • Cross-sector
    • Security & Resilience
    • 5 min read
  5. Week of 29 July 2024

    Systems contained, data exposed: why Columbus’s reassurance outran its evidence

    Columbus could prove it had contained the attack on its systems. It could not yet prove what the stolen data held or whom it exposed. Each claim needs its own evidence, and borrowing from the first to answer the second costs trust.

    • Government
    • Customer & Citizen Experience
    • 5 min read

August 2024

  1. Week of 5 August 2024

    How the August 2024 selloff found brokerages’ capacity limit before the first trade

    On August 5, 2024, customers of large retail brokerages struggled to log in and see balances. The strain sat in the pre-trade path, in three layers with different owners: identity checks, account views and shared vendors. No rule set the target.

    • Financial Services
    • Platforms & Architecture
    • 5 min read
  2. Week of 12 August 2024

    Post-quantum priority starts in the records retention schedule

    NIST’s first post-quantum standards said what to migrate to. For banks, health systems and agencies, the order of migration is set by how long data must stay secret, which makes the retention schedule the first planning document.

    • Cross-sector
    • Platforms & Architecture
    • 5 min read
  3. Week of 19 August 2024

    National Public Data turned the Social Security number into a lookup key

    Once a single broker dataset linked names, addresses, birth dates and Social Security numbers, those facts could still find a customer’s record but could no longer prove who was asking. Enrollment, recovery and high-risk changes each needed a different fix.

    • Cross-sector
    • Customer & Citizen Experience
    • 5 min read
  4. Week of 26 August 2024

    Sea-Tac’s handwritten bag tags were a staffing plan in disguise

    When ransomware took down Port of Seattle systems, the airport kept moving on paper. “Revert to manual” is a promise about people: which work has a paper version, who does it, how long they can sustain it, and who re-keys it afterward.

    • Government
    • Operations & Workforce
    • 5 min read

September 2024

  1. Week of 2 September 2024

    Europe’s AI treaty attached its duties to the public function, not the payroll

    The Council of Europe convention covers AI used by public authorities and by private actors acting on their behalf. That means an agency’s duties follow the service into its contractors, and the boundary of “on their behalf” is where governance gaps will open.

    • Government
    • Regulation & Compliance
    • 5 min read
  2. Week of 9 September 2024

    Why o1’s reasoning summaries added work for clinical AI committees

    OpenAI’s o1 narrated its reasoning just as federal rules on decision support transparency were taking hold. A fluent explanation answers a clinician’s question, not the vendor or the regulator’s, and health systems had to supply three different kinds of transparency themselves.

    • Healthcare
    • Data & AI
    • 5 min read
  3. Week of 16 September 2024

    A hallucination rate is a sales claim, and Texas enforced it like one

    Texas’s settlement with Pieces Technologies applied an old consumer protection statute to a generative AI error rate. Health system buyers can test any such number on three dimensions: what it counts, where it was measured, and how it stays true after updates.

    • Healthcare
    • Regulation & Compliance
    • 5 min read
  4. Week of 23 September 2024

    Helene tested what continuity plans take for granted: staff, signal and signatures

    Continuity plans for local agencies are written for the loss of a building or a system. Helene removed people, connectivity and decision authority across a whole region at once, and each of the three needs its own preparation with its own lead time.

    • Government
    • Operations & Workforce
    • 5 min read
  5. Week of 30 September 2024

    Saline exposed the risk that hides in a hospital’s cheapest line items

    One flooded Baxter plant put IV fluids on allocation nationwide. Low-cost essentials concentrate supply because price pressure rewards scale, so health systems need to manage them by clinical criticality, through four levers that spend-based purchasing ignores.

    • Healthcare
    • Economics & Procurement
    • 5 min read

October 2024

  1. Week of 7 October 2024

    At American Water, containment was the part customers saw

    The largest U.S. water utility kept water flowing after a cyberattack, but switching off its billing portal was the incident as the public experienced it. For utilities and agencies, the customer-facing response is four decisions, and most can be made in advance.

    • Government
    • Customer & Citizen Experience
    • 5 min read
  2. Week of 14 October 2024

    NYDFS wrote no AI rule, and made AI risk part of what the CEO certifies

    New York’s October 2024 letter on AI and cybersecurity added no requirements. Because Part 500 already demands an annual compliance certification signed by the CEO and CISO, it turned four AI risks into evidence those signers must be able to produce.

    • Financial Services
    • Security & Resilience
    • 5 min read
  3. Week of 21 October 2024

    Final and already in court: sorting open banking work by how much you would regret it

    The CFPB’s Section 1033 rule was sued the day it was issued. Banks could not wait out the litigation or comply blindly. The workable approach was to split the program into no-regret work, rule-specific work and work hinging on the contested terms.

    • Financial Services
    • Platforms & Architecture
    • 5 min read
  4. Week of 28 October 2024

    Telehealth’s three policy clocks all ran down in December, so virtual care needed an annual cycle

    After the 2025 fee schedule, a Medicare virtual visit still depended on CMS rulemaking, a congressional extension and a DEA rule. What had looked like a post-emergency transition was a standing condition, with all three clocks converging at year-end, best run as a yearly cycle.

    • Healthcare
    • Customer & Citizen Experience
    • 5 min read

November 2024

  1. Week of 4 November 2024

    After the 2024 election, a rule’s legal form predicted its survival better than its topic

    Election week changed no rule, but it changed the odds for many. The best predictor of which obligations would last was the instrument behind them: statute, a rule still inside the Congressional Review Act window, or guidance and executive orders.

    • Cross-sector
    • Regulation & Compliance
    • 5 min read
  2. Week of 11 November 2024

    FinCEN’s deepfake alert was a job-design problem for three groups of staff

    FinCEN’s November 2024 alert read like a list of red flags for compliance teams. Its harder implication was for the people whose jobs let them act on recognition: onboarding reviewers, service agents and payment operators each needed new decision rights, incentives and escalation paths.

    • Financial Services
    • Operations & Workforce
    • 5 min read
  3. Week of 18 November 2024

    The CFPB reached for payment apps while the customer’s money sat at partner banks

    The larger-participant rule gave federal examiners access to big payment apps and lasted under six months. With Synapse’s collapse fresh, the more durable exposure sat elsewhere: in the law apps already owed and in the banks holding their customers’ funds.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  4. Week of 25 November 2024

    Blue Yonder put process-running vendors at the top of the risk register

    The Blue Yonder ransomware attack disrupted staff scheduling and pay at major retailers. Vendor risk programs built around data protection miss suppliers whose failure stops work, and classifying vendors by what their failure costs changes diligence, contracts and contingency spending.

    • Cross-sector
    • Economics & Procurement
    • 5 min read

December 2024

  1. Week of 2 December 2024

    The CFPB’s data broker proposal exposed a provenance gap that AI programs inherit

    The proposal to treat many data brokers as consumer reporting agencies was withdrawn within six months. Its underlying question, where personal data came from and what it may be used for, applies to data entering, leaving and being repurposed inside every AI program.

    • Cross-sector
    • Data & AI
    • 5 min read
  2. Week of 9 December 2024

    In the RIBridges breach, Rhode Island owned the outage and its vendor owned the evidence

    When attackers breached the vendor-run RIBridges benefits system, the state carried public accountability while the vendor held the systems, logs and forensic work. Contracts for such systems must settle visibility, decision rights, costs and exit before an incident, not during one.

    • Government
    • Economics & Procurement
    • 5 min read
  3. Week of 16 December 2024

    CISA’s encryption advice and the SEC’s recordkeeping cases asked for the same channel

    After the Salt Typhoon telecom intrusions, CISA told targeted people to use end-to-end encrypted messaging, just as off-channel penalties weighed on broker-dealers. The two demands conflict only on channels the firm does not control. An approved channel must be encrypted, captured and usable.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  4. Week of 23 December 2024

    The HIPAA Security Rule proposal’s hardest line was a 72-hour restore

    HHS’s proposed overhaul turned flexible safeguards into specific requirements. Sorted by difficulty, most were controls hospitals already had or evidence they could build. Recovery within 72 hours was different: it needed clinical sequencing, tested capacity and money few systems had budgeted.

    • Healthcare
    • Security & Resilience
    • 5 min read
  5. Week of 30 December 2024

    Treasury’s breach ran through a remote-support key the agency never held

    Attackers reached Treasury workstations with a stolen key that secured a vendor’s cloud remote support service. Remote support is privileged access by another name, and governing it takes four controls along the path from vendor to endpoint, most of which agencies only partly had.

    • Government
    • Security & Resilience
    • 5 min read