Despite the abundance of principles-based cybersecurity guidance provided by regulators, interpreting those principles and turning them into actionable items remains a formidable task.  Nevertheless, financial services professionals have a fiduciary duty to devote best efforts to mitigating cyber risk by building an appropriate risk management solution.  In a guest article, the second in a two-part series, Moshe Luchins, the deputy general counsel and compliance officer of Zweig-DiMenna Associates LLC, provides a practical blueprint to build a cyber-compliance program.  Many aspects of the blueprint are not only applicable to those in the financial industry but to other sectors as well.  The first article explored current regulatory expectations applicable to the financial services sector.  See also “Analyzing and Mitigating Cybersecurity Threats to Investment Managers (Part One of Two)” (May 6, 2015) and Part Two (May 20, 2015).