Under NYDFS 23 NYCRR 500, companies must maintain strict access policies, monitor activity, and protect non-public information. Offshore developer access is a high-risk vector. The regulation makes no distinction between onshore and offshore—only between compliant and non-compliant.
Section 500.07 requires managing access privileges with precision. Offshore accounts must follow least privilege principles, granting only the minimum rights needed. Section 500.14 demands secure access control procedures. Multi-factor authentication is not optional. Section 500.15 requires encryption of data in transit and at rest. Any gap is a violation.
Compliance means knowing who accessed what, when, and why. Logs must be immutable. Session monitoring must be continuous. Remote connections from offshore must pass through hardened, approved channels. No shared accounts. No undocumented connections.