On June 30, 2025, the Cybersecurity and Infrastructure Agency (CISA), the Federal Bureau of Investigation (FBI), the Department of Defense Cyber Crime Center (DC3), and the National Security Agency (NSA) warned U.S. critical infrastructure organizations and other companies that the threat of cyber attacks from Iran-affiliated cyber actors is heightened in the wake of the Iran conflict. The agencies cautioned that the risk is particularly high for Defense Industrial Base (DIB) companies with Israeli ties. This warning was issued shortly after the New York Department of Financial Services provided similar guidance to companies in the financial sector, which we discussed here.

In addition to distributed denial of service (DDoS) and ransomware attacks, the agencies explained that malicious actors may target operational technology (OT) connected to the public internet to perpetrate attacks. A variety of mitigation measures for critical infrastructure companies are listed, such as:

  • Identifying and disconnecting OT and industrial control systems (ICS) assets from the public internet;
  • Ensuring devices and accounts are protected with strong, unique passwords (if not using MFA) and replacing weak or default passwords;
  • Implementing phishing-resistant MFA for OT network access;
  • Applying the latest manufacturer patches for internet-facing systems;
  • Prioritizing the monitoring of user access logs for remote access to OT networks and firmware or configuration changes; and
  • Ensuring incident response and business continuity plans are in place, reviewing and rehearsing these plans, and updating them based on the results.

Click here to read the full guidance.

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Photo of Emily Pehrsson Emily Pehrsson

Emily Pehrsson works across sectors to counsel national and multinational companies on data privacy and cybersecurity issues.

In particular, Emily’s practice includes partnering with clients on the development of new products and services, designing privacy governance programs, and developing privacy disclosures and settings.

Emily Pehrsson works across sectors to counsel national and multinational companies on data privacy and cybersecurity issues.

In particular, Emily’s practice includes partnering with clients on the development of new products and services, designing privacy governance programs, and developing privacy disclosures and settings. Emily also counsels clients on topics such as cyber incident response, compliance with state and federal privacy and cybersecurity regulations, and government investigations. She routinely advises on complex national security and financial privacy regulatory frameworks.

In addition to her regular practice, Emily maintains a pro bono practice counseling small and nonprofit clients on privacy and cybersecurity, supporting domestic violence survivors, and handling criminal matters.

Photo of Caleb Skeath Caleb Skeath

Caleb Skeath advises clients on a broad range of cybersecurity and privacy issues, including cybersecurity incident response, cybersecurity and privacy compliance obligations, internal investigations, regulatory inquiries, and defending against class-action litigation. Caleb holds a Certified Information Systems Security Professional (CISSP) certification.

Caleb specializes…

Caleb Skeath advises clients on a broad range of cybersecurity and privacy issues, including cybersecurity incident response, cybersecurity and privacy compliance obligations, internal investigations, regulatory inquiries, and defending against class-action litigation. Caleb holds a Certified Information Systems Security Professional (CISSP) certification.

Caleb specializes in assisting clients in responding to a wide variety of cybersecurity incidents, ranging from advanced persistent threats to theft or misuse of personal information or attacks utilizing destructive malware. Such assistance may include protecting the response to, and investigation of an incident under the attorney-client privilege, supervising response or investigation activities and interfacing with IT or information security personnel, and advising on engagement with internal stakeholders, vendors, and other third parties to maximize privilege protections, including the negotiation of appropriate contractual terms. Caleb has also advised numerous clients on assessing post-incident notification obligations under applicable state and federal law, developing communications strategies for internal and external stakeholders, and assessing and protecting against potential litigation or regulatory risk following an incident. In addition, he has advised several clients on responding to post-incident regulatory inquiries, including inquiries from the Federal Trade Commission and state Attorneys General.

In addition to advising clients following cybersecurity incidents, Caleb also assists clients with pre-incident cybersecurity compliance and preparation activities. He reviews and drafts cybersecurity policies and procedures on behalf of clients, including drafting incident response plans and advising on training and tabletop exercises for such plans. Caleb also routinely advises clients on compliance with cybersecurity guidance and best practices, including “reasonable” security practices.

Caleb also maintains an active privacy practice, focusing on advising technology, education, financial, and other clients on compliance with generally applicable and sector-specific federal and state privacy laws, including FERPA, FCRA, GLBA, TCPA, and COPPA. He has assisted clients in drafting and reviewing privacy policies and terms of service, designing products and services to comply with applicable privacy laws while maximizing utility and user experience, and drafting and reviewing contracts or other agreements for potential privacy issues.

Photo of Ashden Fein Ashden Fein

Ashden Fein is a vice chair of the firm’s global Cybersecurity practice. He advises clients on cybersecurity and national security matters, including crisis management and incident response, risk management and governance, government and internal investigations, and regulatory compliance.

For cybersecurity matters, Ashden counsels…

Ashden Fein is a vice chair of the firm’s global Cybersecurity practice. He advises clients on cybersecurity and national security matters, including crisis management and incident response, risk management and governance, government and internal investigations, and regulatory compliance.

For cybersecurity matters, Ashden counsels clients on preparing for and responding to cyber-based attacks, assessing security controls and practices for the protection of data and systems, developing and implementing cybersecurity risk management and governance programs, and complying with federal and state regulatory requirements. Ashden frequently supports clients as the lead investigator and crisis manager for global cyber and data security incidents, including data breaches involving personal data, advanced persistent threats targeting intellectual property across industries, state-sponsored theft of sensitive U.S. government information, extortion and ransomware, and destructive attacks.

Additionally, Ashden assists clients from across industries with leading internal investigations and responding to government inquiries related to the U.S. national security and insider risks. He also advises aerospace, defense, and intelligence contractors on security compliance under U.S. national security laws and regulations including, among others, the National Industrial Security Program (NISPOM), U.S. government cybersecurity regulations, FedRAMP, and requirements related to supply chain security.

Before joining Covington, Ashden served on active duty in the U.S. Army as a Military Intelligence officer and prosecutor specializing in cybercrime and national security investigations and prosecutions — to include serving as the lead trial lawyer in the prosecution of Private Chelsea (Bradley) Manning for the unlawful disclosure of classified information to Wikileaks.

Ashden currently serves as a Judge Advocate in the
U.S. Army Reserve.