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Lessons for CISOs from the SolarWinds Breach and SEC Enforcement

By Daniel Garrie, David Cass and Jennifer Deutsch
May 01, 2024

In an era where digital threats loom large, the responsibilities of Chief Information Security Officers (CISOs) have expanded beyond traditional IT security to encompass a broader governance, risk management, and compliance role. The infamous SolarWinds Corp. attack, which compromised numerous public and private organizations globally, illustrates the complex cybersecurity landscape CISOs navigate. The subsequent legal and regulatory responses, including a complaint by the U.S. Securities and Exchange Commission (SEC), underscore the critical role of CISOs in not only safeguarding digital assets but also ensuring compliance with evolving cybersecurity disclosure requirements. This article examines the SolarWinds incident and the SEC's actions to derive essential governance lessons for CISOs.

In 2020, SolarWinds disclosed that it had been subject to a cyberattack, commonly referred to as "SUNBURST." SUNBURST is believed to have been conducted by Russian state-sponsored hackers and affected over 18,000 customers, including government agencies and Fortune 500 companies. See, Complaint, Securities and Exchange Commission v. SolarWinds Corp. et al, Case No. 1:23-cv-09518. Filed Oct. 30, 2023. Attackers compromised the infrastructure of SolarWinds, a leading provider of IT management software, to distribute malicious updates to the company's Orion software.

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