Let’s look at NYDFS-500 section 500.05: “The monitoring and testing shall include continuous monitoring or periodic penetration testing and vulnerability assessments, and shall be done periodically.” This has rightfully raised eyebrows within the industry. Why monitoring instead of testing? These are two different domains. This particular point has three very different options to “achieve” compliance for it. You can monitor, you could pen-test, OR you could do a vulnerability assessment? There are multiple ways this could go, and they’re all incredible different. Moreover, once one regulation comes out like this, other states (or even countries) trust what they are doing, and thus copy what they did.