Potential Risks And Rewards Of Cybersecurity Information Sharing Under CISA

When President Obama signed into law the Cybersecurity Act of 2015, which was designed to facilitate information sharing on cybersecurity threats between the public and private sectors, proponents hailed it as "our best chance yet to help address this economic and national security priority in a meaningful way."¹  Others – including some of the biggest players in the technology industry – decried it as "a thinly disguised surveillance provision," and something to be avoided pending further information on how it would be implemented.  Interim guidance issued earlier this year by the Office of the Director of National Intelligence, the Department of Homeland Security, the Department of Defense, and the Department of Justice, lacked many of the details that industry insiders were waiting for.²  Now, with final guidance having been issued (the "Final Guidance"), in-house counsel have more insight into the potential risks and rewards that await companies who opt to