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Agency Testimony

Milstein raises concerns about Intro 2602 third-party validation

New York City Council · Oct 5, 2026 · starts 5:24:11 · 2 min 35 sec

Milstein explains Cyber Command's role protecting city infrastructure and raises concerns with Intro 2602, saying neither OTI nor Cyber Command has private-sector regulatory experience and deferring to DCWP on enforcement.

Sarah Milstein

Our core mission is to make New York City the most cyber resilient city in the world, and we take this extremely seriously.

Sarah Milstein

New York City is a target for cyber attacks with a technology landscape that is unparalleled among other cities and states.

Sarah Milstein

This requires a unified, comprehensive defense against constant cyber threats.

Sarah Milstein

Our key duties include setting information security policies and standards for the city, directing the city's citywide cyber defense and incident response,

Sarah Milstein

deploying defensive technical and administrative controls, and providing guidance to City Hall and agencies on cyber defense.

Sarah Milstein

In my fairly new role at OTI, it is a privilege to work with our staff and our agency partners in furtherance of this critical mission.

Sarah Milstein

New York City Cyber Command's alignment within OTI has placed the team in a strong position to monitor and respond to wide-ranging cyber threats.

Sarah Milstein

Cybersecurity is continuous work.

Sarah Milstein

In my role, I'm confident we can continue to adapt to a constantly evolving threat landscape.

Sarah Milstein

Simply put, New York City Cyber Command has a 24-7 apparatus in place to defend the city's systems from malicious attacks, regardless of the threat.

Sarah Milstein

the origin.

Sarah Milstein

With that in mind, pre-considered introduction of 2026-2602 would make it unlawful to market, offer for sale, sell or deploy an artificial model, an artificial intelligence model

Sarah Milstein

in New York City that has not received third-party validation or does not have a technical capability to be shut down by a human operator.

Sarah Milstein

The bill would require the director of the Office of Cyber Command to promulgate rules regarding what the third-party validation, assessments, certifications, and disclosure would entail and the qualifications for third-party validators.

Sarah Milstein

To be clear, Cyber Command's core mission is to defend the City of New York's infrastructure from cyber attacks.

Sarah Milstein

We are not subject matter experts on the qualifications for an entity to be considered a third-party validator.

Sarah Milstein

Further, neither an OTI nor Cyber Command have experience regulating the private sector in the way that this legislation would require, and neither would be the best choice to lead this regulatory regime for consumer products.

Sarah Milstein

We defer to DCWP to speak about the private sector policy and enforcement piece.

Sarah Milstein

To that end, DCWP supports the intent of this legislation.

Sarah Milstein

They recommend including robust record-keeping requirements to better allow the agency to conduct affirmative enforcement.

Sarah Milstein

They also note, based on conversations with advocates and sister agencies, that the administration is not certain about the availability or ability of such businesses.

Sarah Milstein

We look forward to hearing from those stakeholders.