Benjamin Nashed

After nearly a decade in the federal government, Benjamin guides clients through the complexities of ocean law and maritime regulations. Benjamin helps shippers, carriers, brokers, truckers, and intermediaries understand and navigate the complex federal regulations governing transportation, ocean shipping, and maritime commerce. He advises on regulatory compliance, negotiates shipping contracts, and provides practical guidance for day-to-day legal questions. As a member of the firm’s Ocean Law team, Benjamin has a strong command of the Ocean Shipping Reform Act and other laws and regulations, with a particular focus on the many regulatory changes enacted in the 2010s and 20s.

Key point: The US Coast Guard’s new cybersecurity rule will transform the security standards and reporting requirements for vessels and marine facilities nationwide over the next three years.

On July 16, 2025, the US Coast Guard’s (USCG) final rule, Cybersecurity in the Marine Transportation System, codified at 33 C.F.R. § 101.600 et seq., went into effect. The final rule establishes cybersecurity requirements for the critical infrastructure owners and operators (CI/OO) of regulated entities (e.g., U.S.-flagged vessels, Outer Continental Shelf (OCS) facilities, and facilities regulated under the Maritime Transportation Security Act of 2002). See 90 Fed. Reg. 6298 (Jan. 17, 2025). These entities were already required to have a Vessel or Facility Security Plan (VSP/FSP) as defined by 33 C.F.R. §§ 104-106. Under the final rule, the CI/OO for these entities have incident reporting obligations, must develop Cybersecurity and Cyber Incident Response Plans, and designate a Cybersecurity Officer charged with implementing the plans. The regulation will be introduced in stages over the next three years, with certain provisions taking effect immediately.