Corporate and healthcare attorney Steven Okoye has been featured in a new national report examining how companies should respond to cybersecurity breaches in the first 48 hours, a period experts describe as the most decisive window in determining regulatory response, financial exposure, and customer trust.
Okoye’s “The First 48 Hours: A Corporate Counsel’s Playbook for Managing a Data Breach” is an article that highlights the evolving role of the General Counsel in managing a company’s response to a cybersecurity crisis, and provides examples of how he has assisted companies in developing compliance, data protection, and governance strategies.
Also published recently as part of a comprehensive series of articles focused on corporate leadership responses to rapidly changing 2025 cybersecurity laws, this article emphasizes the increasing expectations for General Counsel to take swift, well-informed actions following a breach.
A Trusted Voice in Corporate Compliance
Steven Okoye, a New York-based attorney who has expertise in corporate and healthcare law, has developed an extensive knowledge of his clients’ ability to successfully navigate their unique compliance challenges and regulatory frameworks. In addition to developing this knowledge, Steven also assists his clients by protecting privileged communications, establishing and maintaining positive vendor relationships, and ensuring compliance with all applicable reporting requirements at the state and federal levels.
In the interview, Okoye stressed that the countdown begins the moment an incident is detected.
“The first mistake companies make is waiting for confirmation,” Okoye said. “If your IT team tells you data may have been accessed, the clock has already started.”
He emphasized that in today’s legal environment, delays can result in increased liability. Under new privacy laws taking effect this year in Delaware, Iowa, and Minnesota, companies are required to notify regulators and consumers of a breach within tighter timeframes. Many of these laws also mandate annual risk assessments and written cybersecurity policies.
The Expanding Role of General Counsel
Okoye believes the role of General Counsel is to be a steady hand for a company’s corporate team when responding to a cyber attack; “The General Counsel’s actions in the 48 hours immediately following a data breach will reflect their ability to remain calm and provide timely, accurate information to the public, and to show that they were prepared,” he stated.
Okoye went on to say that maintaining attorney client privilege is likely the first and most important obligation of counsel in the aftermath of an attack. “Every document and every meeting note could become evidence unless the privilege is protected,” he cautioned. “It is counsel’s responsibility to oversee the investigation, hire the forensic firm and determine the scope of the firm’s engagement.”
Okoye added that while counsel has historically been responsible for leading a company’s incident response, today counsel must coordinate with other functional areas, including IT, PR, HR, and executive management.
A Changing Legal Landscape
The article places Okoye’s guidance within the broader context of new federal and state cybersecurity developments.
In addition to the state privacy laws, new sector-specific rules have gone into effect for insurers in Rhode Island and financial institutions in Nevada and North Dakota, requiring written security programs and risk-based monitoring.
At the federal level, the Cybersecurity and Infrastructure Security Agency (CISA) allowed its voluntary information-sharing framework to expire in October 2025, while the SEC’s November 2025 decision in the SolarWinds case narrowed liability scope for investor claims but strengthened expectations for transparency around AI-related threats.
“Regulators are signaling that companies must be proactive, not reactive,” Okoye said. “Cybersecurity is no longer just an IT issue—it’s a governance issue.”
The Legal Trend: From Punishment to Partnership
The feature also highlights an encouraging shift in state law. Several new regulations now limit punitive damages for companies that maintain cybersecurity programs aligned with the NIST Cybersecurity Framework. Okoye called this a welcome incentive.
“The law is moving from punishment to partnership,” he said. “States are rewarding organizations that take cybersecurity seriously and invest in prevention.”
Preparedness as the Ultimate Defense
Steven Okoye concluded the interview by offering practical guidance to General Counsel who may have to deal with future breaches. He suggested that General Counsel should update their incident response plans regularly (i.e., quarterly), conduct tabletop exercises, and vet vendors and forensics firms before an incident occurs.
“A breach is going to expose all of your weaknesses,” Okoye stated. “It’s preparation, it’s communications, and it’s integrity that get you through the storm.”
The article establishes Steven Okoye as a leading figure in the national discussion on corporate preparedness for cyber threats, while highlighting his expertise at the intersection of law, governance, and technology.
