Cybersecurity is a rapidly evolving threat without a total solution.  Despite the abundance of principles-based guidance provided to the compliance community from regulators, interpreting those principles and turning them into actionable items remains a formidable task.  Nevertheless, hedge fund managers and other investment advisers 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 hedge fund compliance professionals with a practical blueprint to build a cyber-compliance program.  The first article supplied hedge fund managers with a snapshot of regulatory expectations in the area of cybersecurity.  For more on cybersecurity, see “RCA Panel Outlines Keys for Hedge Fund Managers to Implement a Comprehensive Cybersecurity Program,” Hedge Fund Law Report, Vol. 8, No. 24 (Jun. 18, 2015); and “SEC Guidance Update Suggests a Three-Step Framework for Investment Manager Cybersecurity Programs,” Hedge Fund Law Report, Vol. 8, No. 18 (May 7, 2015).